Bonilla v. White
- Phyllis Hamilton
- 4:20-cv-06396
- U.S. District Court · Northern District of California
- 2
In Bonilla v. White, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the lawsuits faced legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice and closed. The order also directed the clerk to terminate pending motions and return future submissions in those closed cases without filing them.
What happened
Bonilla v. White involved multiple civil-rights lawsuits filed without a lawyer by Steven Wayne Bonilla, a state prisoner. The lawsuits concerned his conviction and the handling of other cases and petitions by state and federal courts.
The court said Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the cases. The court also said that, even if he could proceed without paying, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. White · No. 4:20-cv-06396
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the following 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 named various state courts as defendants and sought relief concerning Bonilla's underlying conviction and the handling of his other self-filed petitions and cases in state and federal court. The order also noted that he had a pending federal petition concerning his conviction in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee restriction
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without prepaying filing fees unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore concluded that he could not proceed without paying the filing fees.
Other legal bars
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those bars.
Disposition
The court dismissed the cases with prejudice. It also stated that the repetitive and allegedly frivolous filings did not create a situation in which the judge's impartiality could reasonably be questioned. The clerk was ordered to terminate all pending motions, close the cases, and 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.