Bonilla v. Yabuno
- Phyllis Hamilton
- 4:20-cv-07827
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Brian E. Hill, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla showed no imminent danger and the lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the clerk was directed to close the cases, terminate pending motions, and return future submissions without filing them.
What happened
In Steven Wayne Bonilla v. Brian E. Hill, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against state courts and state officials. The cases challenged his conviction and the handling of his filings in state and federal court.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he faced an immediate risk of serious physical injury. The complaints did not show that he faced such a risk. The court also said that, even if Bonilla had been allowed to proceed without fees, the lawsuits were barred by several legal rules.
The court dismissed the cases with prejudice, meaning the dismissals were final as to these cases. Judge Phyllis J. Hamilton directed the clerk to terminate all pending motions, close the cases, and return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Yabuno · No. 4:20-cv-07827
- Phyllis Hamilton
- Nov. 9, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included various state courts and state officials. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his self-filed petitions and other cases in state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court, where he had appointed counsel, and was also represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such a danger.
The court further stated that, even if Bonilla had been allowed to proceed without paying the filing fees, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of how each cited rule applied to each case.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Effect
The order ended the multiple cases and treated the dismissals as final. The opinion does not state that the court reached the underlying merits of Bonilla’s challenges to his conviction or to the handling of his other proceedings; instead, it relied on filing-fee restrictions and legal bars to the lawsuits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.