Bonilla v. Blum
- Phyllis Hamilton
- 4:22-cv-04970
- U.S. District Court · Northern District of California
- 2
Bonilla v. County of Alameda: Judge Hamilton dismissed nine related civil-rights cases with prejudice because Bonilla was barred from proceeding without paying filing fees and the suits were legally barred.
Steven Wayne Bonilla's nine related civil-rights cases were dismissed with prejudice. The order also affected his ability to proceed without paying filing fees and directed the clerk to close the cases and reject later submissions.
What happened
In Bonilla v. County of Alameda et al., Steven Wayne Bonilla, a state prisoner representing himself, filed nine nearly identical civil-rights cases against counties and state and federal officials. The cases sought relief related to his conviction and the handling of other state and federal court proceedings.
The court said Bonilla was disqualified from proceeding without paying filing fees unless he faced imminent danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger. It also said that, even if he had been allowed to proceed without paying fees, the lawsuits would be barred by legal rules concerning challenges to convictions, interference with ongoing state proceedings, and certain claims against federal courts.
The court dismissed all nine cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases and return later submissions without filing them. Judge Phyllis J. Hamilton issued the order on September 12, 2022.
The detailed version
- Bonilla v. Blum · No. 4:22-cv-04970
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, identified in the order as a state prisoner and a condemned prisoner, filed nine civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases were numbered 22-cv-4902-PJH, 22-cv-4903-PJH, 22-cv-4904-PJH, 22-cv-4906-PJH, 22-cv-4969-PJH, 22-cv-4970-PJH, 22-cv-5073-PJH, 22-cv-5121-PJH, and 22-cv-5135-PJH. The complaints presented nearly identical claims against several counties and state and federal officials. They sought relief concerning Bonilla's underlying conviction or the way his other cases had been handled by state and federal courts.
The order also noted that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state court proceedings.
Court's reasoning
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time. Bonilla therefore could not proceed without paying the filing fee.
The court separately stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines and authorities. These included the rule generally preventing civil-rights damages claims from undermining an existing conviction, the rule limiting federal interference with ongoing state proceedings, and authorities concerning claims involving federal courts.
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 additional documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.