Bonilla v. Maier
- Phyllis Hamilton
- 4:21-cv-01580
- U.S. District Court · Northern District of California
- 2
In Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and the claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases and the defendants named in those cases.
What happened
In Bonilla v. State of California, Steven Wayne Bonilla filed multiple civil-rights cases without a lawyer against various federal judges, state judges, counties, and federal agencies. He challenged matters involving his conviction and the handling of his other court cases.
The court found that Bonilla could not proceed without paying filing fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed the complaints. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents without filing them.
The detailed version
- Bonilla v. Maier · No. 4:21-cv-01580
- Phyllis Hamilton
- Mar. 9, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion covers the cases assigned docket numbers 21-cv-01345-PJH, 21-cv-01346-PJH, 21-cv-01452-PJH, 21-cv-01489-PJH, 21-cv-01490-PJH, 21-cv-01491-PJH, 21-cv-01520-PJH, 21-cv-01521-PJH, 21-cv-01522-PJH, 21-cv-01523-PJH, 21-cv-01576-PJH, 21-cv-01577-PJH, 21-cv-01578-PJH, 21-cv-01579-PJH, 21-cv-01580-PJH, 21-cv-01581-PJH, and related cases identified in the caption.
The complaints named various federal judges, state judges, counties, and federal agencies as defendants. They raised similar claims concerning Bonilla's underlying conviction and the handling of his other petitions and cases in state and federal court. The opinion also states that Bonilla had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state-court proceedings.
Court's reasoning
The court explained that Bonilla had previously been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without prepaying fees only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed.
The court concluded that the allegations did not show imminent danger at the relevant time. Bonilla therefore could not proceed without prepaying the filing fees. The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under rules and decisions identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed 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.