Bonilla v. Federal Bureau of Investigation
- Phyllis Hamilton
- 4:22-cv-04215
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Coleman, Judge Hamilton barred proceeding without fees and dismissed multiple civil-rights cases with prejudice for lack of imminent danger and other legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also ended pending motions, closed the cases, and directed the clerk to return future submissions in those cases without filing them.
What happened
Steven Wayne Bonilla v. Adrienne L. Coleman, et al. involved multiple nearly identical civil-rights complaints filed by Bonilla, a condemned state prisoner representing himself. He sued a federal judge, state courts, and state and federal officials, seeking relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status and his complaints did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without fees, the lawsuits were barred by other legal rules.
Judge Hamilton dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that future documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Federal Bureau of Investigation · No. 4:22-cv-04215
- Phyllis Hamilton
- July 26, 2022
Background
Steven Wayne Bonilla, a state prisoner under a death sentence, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights law. The complaints presented nearly identical claims against a federal judge, various state courts, and several state and federal officials. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was also represented by counsel in state proceedings concerning that challenge.
Rulings
The court addressed Bonilla's attempt to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner previously disqualified from that status may proceed without fees only if he shows that he faced imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla's allegations did not show such danger. It therefore ruled that he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without fees 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 opinion did not provide a separate claim-by-claim analysis of those grounds.
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 additional 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.