Bonilla v. Coleman
- Phyllis Hamilton
- 4:22-cv-03671
- U.S. District Court · Northern District of California
- 2
Bonilla v. Coleman: Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the defendants in his multiple civil-rights cases; the cases were dismissed with prejudice and closed.
What happened
In Bonilla v. Coleman, Steven Wayne Bonilla, a state prisoner representing himself, filed several nearly identical civil-rights cases against a federal judge, state courts, and state and federal officials. He sought relief concerning his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate serious physical danger when he filed. The court found that his allegations did not show such danger. It also said that, even if he could proceed without paying, the lawsuits would be barred by legal rules concerning challenges to convictions, ongoing state proceedings, and review of other courts’ decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return any further documents submitted in them without filing them.
The detailed version
- Bonilla v. Coleman · No. 4:22-cv-03671
- Phyllis Hamilton
- July 26, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. Bonilla named a federal judge, various state courts, and several state and federal officials as defendants. The order states that he sought relief related to his underlying conviction or to the way his other state and federal cases had been handled.
The order also states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings concerning his custody.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying may do so only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show that he was in such danger.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those grounds.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to 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.