Bonilla v. United States District Court
- Phyllis Hamilton
- 4:20-cv-04309
- U.S. District Court · Northern District of California
- 2
In Bonilla v. United States District Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and legal barriers applied.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, preventing those cases from continuing; the named federal and state judges, municipalities, and other court officials were defendants in those cases.
What happened
In Bonilla v. United States District Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits under a federal law allowing claims against officials who violate constitutional rights. He named federal and state judges, municipalities, and other court officials, and sought relief concerning his conviction and the handling of his other court cases and petitions.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger. It also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and prior decisions.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also rejected any basis for questioning her impartiality and directed the clerk to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. United States District Court · No. 4:20-cv-04309
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without counsel under 42 U.S.C. § 1983. The complaints named various federal judges, state judges, municipalities, and other court officials. The court said the complaints presented very similar claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other petitions and cases. The opinion also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state court proceedings.
Filing-fee restriction
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only when the complaint shows that the prisoner was in imminent danger of serious physical injury at the time of filing. The court found that Bonilla’s allegations did not show imminent danger, so he could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee 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 opinion does not separately explain which doctrine applied to which case or claim.
Ruling
The court dismissed the cases with prejudice. It also concluded that the circumstances did not provide a basis for questioning the undersigned judge’s impartiality. 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.