Bonilla v. State of California
- Phyllis Hamilton
- 4:21-cv-01189
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice after ruling Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla and the defendants in the listed cases; all of the cases were closed, and pending motions were terminated.
What happened
In Steven Wayne Bonilla v. Judge Beth L. Freeman, et al., Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against federal and state judges, court staff, and government agencies. His complaints sought relief related to his conviction and the handling of his petitions and other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying filing fees because he was disqualified from that status under federal law and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules and prior court decisions.
Judge Phyllis J. Hamilton dismissed all of the listed cases with prejudice, terminated the pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. State of California · No. 4:21-cv-01189
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against government actors. The listed cases named various federal judges, state judges, court staff, and state and federal agencies as defendants. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his petitions and other cases in state and federal courts.
The order noted that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel, and that he was also represented by counsel in state-court proceedings. The order identified the cases as 21-cv-01090-PJH, 21-cv-01163-PJH, 21-cv-01188-PJH, 21-cv-01189-PJH, 21-cv-01190-PJH, 21-cv-01223-PJH, 21-cv-01224-PJH, 21-cv-01225-PJH, 21-cv-01242-PJH, 21-cv-01243-PJH, 21-cv-01244-PJH, 21-cv-01245-PJH, 21-cv-01246-PJH, 21-cv-01247-PJH, 21-cv-01248-PJH, 21-cv-01249-PJH, and 21-cv-01250-PJH.
Filing-fee determination
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he could show that he was under imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. It therefore ruled that Bonilla could not proceed without paying the filing fee.
Additional grounds for dismissal
The court stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would still 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 separately analyze which cited rule applied to which individual case or claim.
The court also addressed a recusal issue because Bonilla named the undersigned judge as a defendant in one case. It found that the repetitive and allegedly frivolous nature of the filings did not provide a reason to question the judge’s impartiality. The footnote states that the complaint naming the judge raised no specific allegations against her.
Disposition
The order 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 those closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.