Bonilla v. Davilla
- Phyllis Hamilton
- 4:20-cv-08505
- U.S. District Court · Northern District of California
- 2
Bonilla v. Simmons: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent-danger exception and identifying legal barriers to the suits.
Steven Wayne Bonilla and the five listed civil-rights cases; the cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons, et al., Steven Wayne Bonilla, a state prisoner, filed several self-represented civil-rights lawsuits against various federal and state court judges. He challenged his conviction and the way courts handled his habeas petitions and other cases.
The court said Bonilla had previously been disqualified from filing lawsuits without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury. The court found that his complaints did not show that danger. It also said that, even if his fee applications were granted, the lawsuits would be barred by several legal rules concerning challenges to convictions, interference with ongoing state proceedings, and suits against judges or courts.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future filings without filing them. Judge Phyllis J. Hamilton also concluded that her impartiality could not reasonably be questioned based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Davilla · No. 4:20-cv-08505
- Phyllis Hamilton
- Dec. 29, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The defendants included various federal and state court judges. The complaints raised similar issues and sought relief related to Bonilla’s underlying conviction and the handling of his self-represented habeas petitions and other cases.
The opinion noted that Bonilla had a pending federal habeas petition with appointed counsel and was represented by counsel in state habeas proceedings. The court also noted that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaint.
Court’s Analysis
The court found that the allegations did not show that Bonilla faced the required immediate danger of serious physical injury. The court further stated that, even if his applications to proceed without paying filing fees were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, concerning civil-rights claims that would undermine a conviction; Younger v. Harris, concerning federal interference with ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
The court also addressed judicial impartiality. It concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. Citing United States v. Holland, the court stated that, absent legitimate grounds for disqualification, a judge has a duty to decide assigned cases.
Disposition
The court dismissed all five cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any additional 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.