Bonilla v. Sweet
- Phyllis Hamilton
- 4:22-cv-05348
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Steven Barnes, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in those cases.
What happened
In Steven Wayne Bonilla v. Judge Steven Barnes et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against state courts and judges. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from filing without fees, and his complaints did not show imminent danger of serious physical injury. The court also said the lawsuits would be barred for other legal reasons, including rules protecting criminal convictions and ongoing court proceedings from this type of challenge.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Sweet · No. 4:22-cv-05348
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, a federal law allowing claims for certain violations of constitutional rights by state actors. The complaints named numerous state courts and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts. The opinion states that he was proceeding without a lawyer in these civil-rights cases.
Filing-fee restriction
The court addressed Bonilla's request, or possible request, to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla had been disqualified under that provision and that his allegations did not show imminent danger at the relevant time. He therefore could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis explaining which cited bar applied to which case or claim.
Ruling and disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.