Bonilla v. Freeman
- Phyllis Hamilton
- 4:21-cv-01090
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also directed the clerk to close those cases, terminate pending motions, and return later submissions without filing them.
What happened
In Bonilla v. Freeman, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against federal and state judges, court staff, and government agencies. His claims concerned his conviction and how courts handled his earlier cases.
The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he could proceed without fees, the lawsuits were barred by other legal rules. It dismissed the cases with prejudice, meaning the dismissals ended these cases and barred refiling these same claims in these cases.
Judge Phyllis J. Hamilton also concluded that the filings did not require her to step aside because of a reasonable question about her impartiality. She ordered the clerk to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submitted in them.
The detailed version
- Bonilla v. Freeman · No. 4:21-cv-01090
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a law that allows certain civil-rights claims against state actors. The complaints named federal judges, state judges, court staff, and state and federal agencies as defendants. The opinion says the complaints presented similar claims seeking relief related to Bonilla’s underlying conviction and to the handling of his earlier filings in state and federal courts.
The opinion also states that Bonilla had a pending federal petition concerning his imprisonment in the same court, with appointed counsel, and was represented by counsel in state-court proceedings concerning his imprisonment.
Fee-free filing and legal bars
The court explained that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was under imminent danger of serious physical injury when he filed. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fee in these cases.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under rules and precedents identified in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each case or claim under those authorities.
Ruling and case status
The court dismissed the cases with prejudice. The order also addressed the fact that Bonilla named the presiding judge as a defendant in one case. It concluded that the filings did not create a reasonable question about the undersigned judge’s impartiality based on their repetitive and frivolous nature.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.