Bonilla v. Heideberger
- Phyllis Hamilton
- 4:20-cv-07789
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Brian E. Hill, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and several legal barriers.
Steven Wayne Bonilla, who filed the cases without a lawyer, and the various state courts and state officials he named as defendants.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases against various state courts and state officials. The cases challenged his conviction and the handling of his other cases and petitions.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he showed that he faced imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without fees, 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, terminated all pending motions, and ordered the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Heideberger · No. 4:20-cv-07789
- Phyllis Hamilton
- Nov. 9, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The defendants included various state courts and state officials. The complaints presented similar claims seeking relief related to Bonilla’s underlying conviction and to the handling of his petitions and other cases in state and federal courts.
The opinion lists these related case numbers: 20-cv-07783-PJH, 20-cv-07784-PJH, 20-cv-07785-PJH, 20-cv-07786-PJH, 20-cv-07788-PJH, 20-cv-07789-PJH, 20-cv-07790-PJH, 20-cv-07827-PJH, 20-cv-07829-PJH, 20-cv-07830-PJH, 20-cv-07831-PJH, and 20-cv-07832-PJH.
Court’s reasoning
The court addressed Bonilla’s possible request to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show imminent danger, so Bonilla could not proceed without paying the fees.
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 opinion did not resolve the underlying claims on their merits.
The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. The opinion does not identify a separate recusal motion or state that one was separately granted or denied.
Disposition
The court dismissed the cases with prejudice. It directed the clerk 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.