Bonilla v. Simmons
- Phyllis Hamilton
- 4:22-cv-00268
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Delgado, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without paying and the suits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the cases were closed. The order also ended pending motions and directed the clerk to return later documents submitted in those closed cases without filing them.
What happened
In Bonilla v. Delgado, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer against numerous federal and state judges. He challenged his conviction and how other court cases were handled.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed an immediate serious danger of physical injury. The complaints did not show that danger. The court also said the lawsuits would be barred for other legal reasons even if he could proceed without paying.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Simmons · No. 4:22-cv-00268
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases named dozens of federal and state judges as defendants and presented nearly identical claims. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other cases in state and federal courts.
The order states that Bonilla is a condemned state prisoner with a pending federal petition challenging his custody, for which he has appointed counsel. It also states that he is represented by counsel in state court proceedings.
Court’s reasoning
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 a prisoner with this type of filing history to proceed without paying only if he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under several legal doctrines and decisions, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and the authority of federal courts over other courts. The opinion did not decide the underlying allegations on their merits.
The court also rejected any suggestion that the judge needed to step aside because of the repetitive and allegedly frivolous filings. A footnote states that Bonilla named the judge as a defendant in one of the cases but made no specific allegations against that judge.
Disposition
The court dismissed the cases with prejudice. It ordered 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 covers the listed case numbers, including 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.