Bonilla v. Masumaga
- Phyllis Hamilton
- 4:20-cv-07832
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Hill, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits were legally barred.
Steven Wayne Bonilla, whose multiple civil-rights cases were dismissed with prejudice and closed; the defendants named in those cases were not required to litigate the claims further in those actions.
What happened
In Bonilla v. Brian E. Hill, et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights cases against state courts and officials. He challenged his conviction and the handling of his state and federal court cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from that status and did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules.
Judge Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Masumaga · No. 4:20-cv-07832
- Phyllis Hamilton
- Nov. 9, 2020
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state actors for alleged violations of federal rights. He represented himself in these cases. The complaints named various state courts and state officials as defendants and presented similar claims concerning Bonilla’s underlying conviction and the handling of his self-represented habeas petitions and other cases.
The opinion also states that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
Proceeding Without Filing Fees
Bonilla sought, or appeared to seek, permission to proceed without paying filing fees. The court stated that he had already been disqualified from that status under 28 U.S.C. § 1915(g), which limits such permission for prisoners who have accumulated qualifying prior dismissals unless they were in imminent danger of serious physical injury when they filed.
The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without paying the filing fees.
Other Grounds for Dismissal
The court further stated that, even if an application to proceed without filing fees had been granted, the lawsuits would be barred under 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 explain which of these grounds applied to which case or claim.
Disposition
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings. 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.
Classification
This is a procedural order because the court disposed of the cases based on the prisoner filing-fee restriction and other threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.