Bonilla v. Alameda County District Attorney's Office
- Phyllis Hamilton
- 4:22-cv-04214
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying filing bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return later submissions without filing them.
What happened
Bonilla v. Alameda County District Attorney’s Office involved Steven Wayne Bonilla, a state prisoner who filed multiple civil-rights lawsuits without a lawyer. The complaints were nearly identical and challenged his conviction or how state and federal courts handled his other cases.
The court found that Bonilla’s allegations did not show he was in immediate danger of serious physical injury when he filed. As a result, he could not use the fee waiver available to qualifying prisoners. The court also said that, even if the fee waiver had been granted, other legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Alameda County District Attorney's Office · No. 4:22-cv-04214
- Phyllis Hamilton
- July 26, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The cases presented nearly identical claims. Bonilla named a federal judge, various state courts, and several state and federal officials as defendants. The complaints sought relief concerning his underlying conviction or the handling of his other state and federal cases.
The opinion also states that Bonilla was a condemned prisoner with a pending federal petition concerning his imprisonment in the same court, where he had appointed counsel. It states that he was represented by counsel in state-court proceedings as well.
Filing-fee restriction
The court addressed whether Bonilla could proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without paying the fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying the fee unless that exception applied.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. Therefore, Bonilla could not proceed without paying the filing fee.
Other grounds cited by the court
The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate analysis of each rule in the quoted text.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Judge Phyllis J. Hamilton signed the order on July 26, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.