Bonilla v. Jackson
- Phyllis Hamilton
- 4:21-cv-01249
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Freeman, Judge Hamilton dismissed the multiple civil-rights cases with prejudice after denying fee-free filing and finding additional legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the listed defendants were not required to litigate those cases further in the district court.
What happened
In Steven Wayne Bonilla v. Judge Beth L. Freeman, et al., the plaintiff, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. The complaints named federal and state judges, court staff, and state and federal agencies. They raised similar challenges to his conviction and to how courts handled his other cases and petitions.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from fee-free filing unless he showed an immediate danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules concerning challenges to convictions, interference with ongoing cases, and limits on lawsuits against judges and courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases. The clerk was also ordered to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Jackson · No. 4:21-cv-01249
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal civil-rights statute. He represented himself in these lawsuits. The complaints named various federal judges, state judges, court staff, and state and federal agencies as defendants. The court said the cases presented very similar claims about Bonilla’s underlying conviction and about the handling of his self-filed habeas petitions and other cases.
The opinion also noted that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings challenging his imprisonment.
Court’s Analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when it was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that rule. It found that the allegations in these complaints did not show an immediate danger of serious physical injury at the time of filing.
The court further stated that, even if a fee-waiver application were granted, the lawsuits would still be barred under rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and limits on suits against federal judges and courts. The opinion also rejected any suggestion that the judge’s impartiality could reasonably be questioned merely because Bonilla had filed repetitive and allegedly frivolous cases. A footnote stated that Bonilla named Judge Hamilton as a defendant in one case but made no specific allegations against her in that complaint.
Disposition
The court dismissed the 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 further documents Bonilla submitted in the closed cases. The opinion does not separately identify a disposition for each docket number beyond stating that the multiple cases were dismissed with prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.