Bonilla v. Lloyd
- Phyllis Hamilton
- 4:21-cv-03805
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Yvonne Gonzalez-Rogers, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla was barred from proceeding without paying filing fees and the suits faced additional legal bars.
Steven Wayne Bonilla and the six listed civil-rights cases; the court terminated their pending motions, closed the cases, and ordered future submissions returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits under a federal law against various federal judges and a correctional officers’ association. He sought relief concerning his conviction and the handling of his other state and federal cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from proceeding without them and had not shown that he faced an immediate danger of serious physical injury when he filed the complaints. The court also ruled that, even if he could proceed without paying, the lawsuits would be barred under several legal doctrines and dismissed the cases with prejudice.
The order also stated that the filings did not provide a basis to question Judge Phyllis J. Hamilton’s impartiality. Judge Hamilton directed the clerk to terminate all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Lloyd · No. 4:21-cv-03805
- Phyllis Hamilton
- May 28, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various federal judges and a correctional officers’ association as defendants. Bonilla presented similar claims in the cases and sought relief related to his underlying conviction or the way state and federal courts had handled his other cases.
The opinion states that Bonilla also had a pending federal petition concerning his imprisonment, with appointed counsel, and was represented by counsel in state proceedings concerning the same general subject matter.
Filing-fee restriction
The court explained that Bonilla had been disqualified from proceeding in the cases without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other legal bars and disposition
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine’s application to each complaint.
The court dismissed the cases with prejudice. It also directed the clerk to terminate all pending motions and close the cases. The clerk was instructed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Impartiality
The court stated that the cases did not present circumstances in which Judge Phyllis J. Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings. Judge Hamilton entered the order on May 28, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.