Bonilla v. White
- Phyllis Hamilton
- 4:21-cv-00847
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Jackson, Judge Hamilton dismissed multiple civil-rights cases with prejudice and ruled that Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The clerk was directed to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
Steven Wayne Bonilla filed multiple civil-rights cases against various federal and state court judges, challenging his conviction and how courts handled his other cases. Judge Hamilton’s order addressed all of these cases together.
Bonilla was a state prisoner and had filed the cases without a lawyer. Because he had previously been barred from proceeding without paying filing fees, he had to show that he faced an immediate risk of serious physical injury when he filed. The court found that his allegations did not make that showing.
Judge Hamilton ruled that Bonilla could not proceed without paying filing fees and dismissed the cases with prejudice. The court also said that the lawsuits would be barred for other reasons even if fee-free filing had been allowed, terminated all pending motions, and ordered the clerk to close the cases.
The detailed version
- Bonilla v. White · No. 4:21-cv-00847
- Phyllis Hamilton
- Feb. 11, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He is described as a condemned prisoner and as having a pending federal petition challenging his custody, with appointed counsel, as well as state-court proceedings in which he was represented by counsel.
The complaints named various federal and state court judges as defendants. The cases presented similar claims concerning Bonilla’s underlying conviction and the way state and federal courts handled his other petitions and cases.
Filing-fee status and dismissal
The order states that Bonilla had previously been disqualified from proceeding without paying the filing fee 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. The court found that the allegations did not show such danger. It therefore ruled that he could not proceed without paying the filing fee.
The court further stated that, even if Bonilla had been allowed to proceed without paying the fee, 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 court dismissed the cases with prejudice.
Other rulings and case status
The court rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.