Bonilla v. Seeborg
- Phyllis Hamilton
- 4:22-cv-01225
- U.S. District Court · Northern District of California
- 2
In Bonilla v. White, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his lawsuits were barred.
Steven Wayne Bonilla and the multiple related civil-rights cases he filed; the order also concerned the federal and state judges he named as defendants.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple civil-rights cases under federal law without a lawyer. The cases named dozens of federal and state judges and challenged his conviction or how other courts handled his cases.
The court found that Bonilla could not proceed without paying filing fees because he had previously been barred from that status and his complaints did not show imminent danger of serious physical injury when filed. The court also said the lawsuits would be legally barred even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Seeborg · No. 4:22-cv-01225
- Phyllis Hamilton
- Mar. 14, 2022
Background
The order addresses multiple related cases: Nos. 22-cv-1119-PJH, 22-cv-1121-PJH, 22-cv-1122-PJH, 22-cv-1130-PJH, 22-cv-1224-PJH, 22-cv-1225-PJH, 22-cv-1546-PJH, 22-cv-1547-PJH, 22-cv-1548-PJH, and 22-cv-1549-PJH. Steven Wayne Bonilla, identified as a state prisoner, filed the cases without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute used to sue certain government actors for violating federal rights. The order states that Bonilla is a condemned prisoner and has a pending federal petition concerning his custody in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings.
Claims and preliminary filing-fee issue
The complaints presented nearly identical claims and named dozens of federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.
Bonilla was subject to 28 U.S.C. § 1915(g), which generally prevents a prisoner with qualifying prior dismissals from proceeding without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other legal bars and disposition
The court further held that, even if Bonilla’s request to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in the order, including rules concerning challenges to convictions, interference with ongoing state proceedings, attacks on federal court proceedings, and claims against judges for judicial acts. The court did not decide the underlying validity of Bonilla’s conviction or the merits of the nearly identical civil-rights claims.
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not provide a basis to question the undersigned judge’s impartiality, including because Bonilla named that judge as a defendant in one case. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.