Bonilla v. Simmons
- Phyllis Hamilton
- 4:22-cv-00189
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Delgado, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the named federal and state judge defendants were affected because the cases against them were closed.
What happened
In Bonilla v. Delgado, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer under a federal civil-rights law. He named dozens of federal and state judges and sought relief related to his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules concerning challenges to convictions, interference with ongoing proceedings, and similar claims.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also ordered the clerk to return future documents Bonilla submitted in the closed cases without filing them. Judge Phyllis J. Hamilton further stated that her impartiality could not reasonably be questioned based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Simmons · No. 4:22-cv-00189
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints without a lawyer. The complaints asserted civil-rights claims under 42 U.S.C. § 1983, a federal law allowing claims for certain violations of constitutional rights by state actors. The complaints named dozens of federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way other state and federal cases had been handled.
The caption lists these related case numbers: 22-cv-0184-PJH, 22-cv-0185-PJH, 22-cv-0188-PJH, 22-cv-0189-PJH, 22-cv-0258-PJH, 22-cv-0259-PJH, 22-cv-0260-PJH, 22-cv-0268-PJH, 22-cv-0269-PJH, 22-cv-0270-PJH, 22-cv-0271-PJH, 22-cv-0272-PJH, 22-cv-0273-PJH, 22-cv-0274-PJH, 22-cv-0276-PJH, 22-cv-0277-PJH, and 22-cv-0278-PJH.
Filing-fee determination
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits such a prisoner to proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show imminent danger. Bonilla therefore could not proceed without paying the filing fee.
Other grounds for dismissal
The court added that, even if an application to proceed without paying had been 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 separately explain how each cited rule applied to each complaint, but it stated that these cases could not proceed on those grounds.
Impartiality
The court stated that the cases did not present circumstances in which the undersigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. A footnote stated that Bonilla named the undersigned judge as a defendant in case number 22-cv-0259-PJH, but raised no specific allegations against that judge in the complaint excerpt provided.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It further directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and other threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.