Bonilla v. Ruling by Toni G. Cantil-Sakauye
- Phyllis Hamilton
- 4:20-cv-04319
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Various Defendants, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims faced legal bars.
Steven Wayne Bonilla's 16 related civil-rights cases were dismissed with prejudice, and the various judges, municipalities, and other court officials named as defendants were affected by the cases' closure.
What happened
In Bonilla v. Various Defendants, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits under federal law. The complaints named various federal judges, state judges, municipalities, and other court officials, and sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla was barred from proceeding without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also stated that, even if he could proceed without fees, the lawsuits would be barred by other legal rules and prior decisions. It dismissed the cases with prejudice, meaning the dismissals were final under the order, terminated pending motions, and closed the cases.
Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned. The clerk was directed to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Ruling by Toni G. Cantil-Sakauye · No. 4:20-cv-04319
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The order addresses 20-cv-04301-PJH, 20-cv-04303-PJH, 20-cv-04304-PJH, 20-cv-04305-PJH, 20-cv-04306-PJH, 20-cv-04307-PJH, 20-cv-04308-PJH, 20-cv-04309-PJH, 20-cv-04310-PJH, 20-cv-04311-PJH, 20-cv-04313-PJH, 20-cv-04315-PJH, 20-cv-04316-PJH, 20-cv-04317-PJH, 20-cv-04318-PJH, and 20-cv-04319-PJH.
The complaints named various federal judges, state judges, municipalities, and other court officials. The court stated that the complaints presented very similar claims seeking relief concerning Bonilla's underlying conviction or the handling of his pro se habeas petitions and other cases. The order also noted that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
Filing-fee status and legal bars
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying fees only when the complaint shows that the prisoner was under imminent danger of serious physical injury at the time of filing. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately explain how each cited decision applied to each complaint.
Ruling
The court dismissed the cases with prejudice. The order also stated that the cases were not ones in which the judge's impartiality might reasonably be questioned. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
Judge Phyllis J. Hamilton signed the order on July 6, 2020. The opinion's caption does not identify the individual defendants by name; it refers to them collectively as various defendants and officials.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.