Bonilla v. Mayfield
- Phyllis Hamilton
- 4:21-cv-01577
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the named federal judges, state judges, counties, and federal agencies were defendants in those cases.
What happened
In Steven Wayne Bonilla v. State of California, et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights lawsuits against federal judges, state judges, counties, and federal agencies. The cases concerned his conviction and the handling of his other cases and habeas petitions.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees 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 fee waivers were granted, the lawsuits would be barred by several legal rules and decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Mayfield · No. 4:21-cv-01577
- Phyllis Hamilton
- Mar. 9, 2021
Background
Steven Wayne Bonilla, a condemned prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named various federal judges, state judges, counties, and federal agencies as defendants. The court said the complaints presented similar claims seeking relief concerning Bonilla's underlying conviction or the handling of his other petitions and cases in state and federal courts.
The order also noted that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel and was represented by counsel in state-court proceedings concerning such a petition.
Filing-fee ruling
The court addressed Bonilla's ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified under that statute and that his allegations did not show the required danger. The court therefore ruled that he could not proceed without paying the filing fees.
Other legal bars and disposition
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would 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 provide a separate claim-by-claim explanation of which cited bar applied to which case.
The court 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. The order disposed of the cases on filing-fee and other legal-bar grounds rather than deciding the underlying challenges to Bonilla's conviction or to the handling of his other proceedings.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.