Bonilla v. Hamilton
- Phyllis Hamilton
- 4:21-cv-01163
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and several legal bars.
Steven Wayne Bonilla and the multiple civil-rights cases he filed; the named federal and state defendants; and the handling of future filings in the closed cases.
What happened
In Bonilla v. Judge Beth L. Freeman, et al., Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. He sued federal and state judges, court staff, and state and federal agencies, raising similar claims about his conviction and how courts handled his other cases.
The court ruled that Bonilla could not proceed without paying the required filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he had been allowed to use that fee-waiver process, the lawsuits were barred by several legal rules and prior decisions.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also directed the clerk to return future documents Bonilla submitted in those closed cases without filing them. Judge Phyllis J. Hamilton further concluded that recusal was not required based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Hamilton · No. 4:21-cv-01163
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a statute used to seek relief for certain civil-rights violations. He represented himself in these cases. The complaints named various federal judges, state judges, court staff, and state and federal agencies as defendants. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction and the handling of his other petitions and court cases.
The opinion also noted that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment.
Fee-waiver ruling
The court addressed whether Bonilla could proceed without paying the required filing fees under the federal fee-waiver process. It stated that 28 U.S.C. § 1915(g) disqualified him from proceeding that way unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The allegations did not show that he faced such danger at that time. The court therefore ruled that he could not proceed under that fee-waiver process.
Other legal bars and disposition
The court added that, even if Bonilla’s application to proceed without paying the filing fees had been granted, the lawsuits would be barred under rules or doctrines identified through Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not assign a separate ruling to each individual case or explain which cited bar applied to each complaint. It ordered that the cases be dismissed with prejudice.
The court also concluded that its impartiality could not reasonably be questioned because of the repetitive and frivolous filings. A footnote stated that Bonilla named Judge Hamilton as a defendant in one case but made no specific allegations against her. The clerk was ordered to terminate all pending motions and close the cases, and 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.