Bonilla v. Arnold
- Phyllis Hamilton
- 4:22-cv-05347
- 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 fees and the suits 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 to return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Steven Barnes and others, Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state courts and judges. He sought relief related to his conviction and the handling of his other court cases.
The court found that Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that status and had not shown an imminent danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying fees, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice, terminated the pending motions, and closed the cases.
Judge Phyllis J. Hamilton signed the order on September 26, 2022.
The detailed version
- Bonilla v. Arnold · No. 4:22-cv-05347
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints presented nearly identical claims and named numerous state courts and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts. The order also notes that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that petition.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the fees.
Other Bars Identified by the Court
The court further stated that, even if Bonilla had been allowed to proceed without paying fees, 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 order did not provide a separate claim-by-claim analysis explaining which bar applied to which allegation.
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.