Bonilla v. Broomfield
- Phyllis Hamilton
- 4:21-cv-08888
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Broomfield, Judge Hamilton dismissed three civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits faced other legal bars.
Steven Wayne Bonilla’s three cases were dismissed with prejudice. The defendants in those cases were affected by the closure of the actions, and the clerk was directed to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Bonilla v. Broomfield, Steven Wayne Bonilla, a state prisoner representing himself, filed three similar civil-rights cases under a federal law allowing claims against government actors. He sought relief related to his conviction or the handling of his other state and federal cases.
The court said Bonilla was barred from proceeding without paying filing fees because he had previously brought enough unsuccessful cases to trigger that restriction. The court also found that his allegations did not show he faced an immediate risk of serious physical injury when he filed the complaints. The court further said that, even if he could proceed without fees, the lawsuits were barred by other legal doctrines and statutes identified in the order.
The court dismissed all three cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases and return any further documents without filing them. Judge Phyllis J. Hamilton signed the order.
The detailed version
- Bonilla v. Broomfield · No. 4:21-cv-08888
- Phyllis Hamilton
- Dec. 8, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed three similar complaints under 42 U.S.C. § 1983, a federal civil-rights statute. He represented himself in these cases. The complaints sought relief concerning his underlying conviction or the handling of other cases by state and federal courts. The order also notes that Bonilla had a pending federal petition concerning his conviction in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
Bonilla sought, or appeared to seek, permission to proceed without paying the filing fee. The court held that 28 U.S.C. § 1915(g) disqualified him from proceeding without that payment unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
Other legal bars
The court added that, even if Bonilla’s application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order does not separately explain how each doctrine applied to each complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and it ordered that any additional documents Bonilla submitted in the closed cases be returned without filing. The dismissal rested on the filing-fee restriction and the stated legal bars rather than an adjudication of the underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.