Bonilla v. FBI
- Phyllis Hamilton
- 4:20-cv-06369
- U.S. District Court · Northern District of California
- 2
In Bonilla v. FBI, Judge Hamilton dismissed the cases with prejudice because Bonilla showed no imminent danger and his claims were barred.
Steven Wayne Bonilla and the defendants in his multiple civil-rights cases, including various state courts identified in the complaints.
What happened
Bonilla v. FBI involved multiple civil-rights lawsuits filed by Steven Wayne Bonilla, a condemned state prisoner representing himself. He challenged his conviction and the handling of his other state and federal court cases, naming various state courts as defendants.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from that payment method unless he faced an immediate risk of serious physical injury. His complaints did not show such a risk. The court also said that, even if he had been allowed to proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing proceedings, and court actions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. FBI · No. 4:20-cv-06369
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order addresses the case numbers 20-cv-06002-PJH, 20-cv-06003-PJH, 20-cv-06114-PJH, 20-cv-06293-PJH, 20-cv-06294-PJH, 20-cv-06295-PJH, 20-cv-06296-PJH, 20-cv-06329-PJH, 20-cv-06330-PJH, 20-cv-06338-PJH, 20-cv-06339-PJH, 20-cv-06341-PJH, 20-cv-06342-PJH, 20-cv-06366-PJH, 20-cv-06367-PJH, 20-cv-06369-PJH, 20-cv-06370-PJH, 20-cv-06394-PJH, 20-cv-06395-PJH, 20-cv-06396-PJH, 20-cv-06397-PJH, and 20-cv-06461-PJH.
The complaints concerned Bonilla’s underlying conviction and the handling of his self-represented petitions and other cases by state and federal courts. The order also notes that he had a pending federal petition challenging his detention in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that payment method may proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla’s allegations did not show that danger.
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately assign each cited principle to particular claims or cases.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It cited the rule that, absent legitimate grounds for disqualification, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.