Bonilla v. LaPorte
- Phyllis Hamilton
- 4:22-cv-05355
- U.S. District Court · Northern District of California
- 2
Bonilla v. Barnes: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and other legal barriers applied.
Steven Wayne Bonilla and the related cases he filed against numerous state courts and state judges. The cases were dismissed with prejudice and closed.
What happened
In Bonilla v. Judge Steven Barnes et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against state courts and judges. He challenged his conviction and how other state and federal cases were handled.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he showed imminent danger of serious physical injury. The court found no such danger and said that, even if he could proceed without fees, legal rules would bar the lawsuits. It dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future filings without filing them.
Judge Phyllis J. Hamilton issued the order on September 26, 2022. The order resolved the cases on filing and other legal-bar grounds rather than deciding whether Bonilla’s underlying claims were correct.
The detailed version
- Bonilla v. LaPorte · No. 4:22-cv-05355
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983. The order covers numerous related case numbers, including 22-cv-5345-PJH, 22-cv-5346-PJH, 22-cv-5347-PJH, 22-cv-5348-PJH, 22-cv-5351-PJH through 22-cv-5359-PJH, 22-cv-5360-PJH, 22-cv-5361-PJH, 22-cv-5362-PJH, 22-cv-5363-PJH, 22-cv-5391-PJH through 22-cv-5393-PJH, and 22-cv-5401-PJH through 22-cv-5403-PJH and 22-cv-5406-PJH.
Bonilla’s claims were nearly identical. He named numerous state courts and state judges as defendants and sought relief concerning his underlying conviction and the handling of his other cases 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 custody-related proceedings.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees. That restriction has an exception when a prisoner shows that he was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show imminent danger at that time. As a result, Bonilla could not proceed without paying the required fees.
Other legal barriers
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the order, including rules concerning challenges to criminal convictions, federal interference with ongoing state proceedings, restrictions on certain challenges to federal court proceedings, and limits on suing federal courts. The order did not decide the merits of Bonilla’s underlying claims.
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. Judge Phyllis J. Hamilton signed the order on September 26, 2022.
Classification basis
This is a procedural order because the court disposed of the cases based on the filing-fee restriction and other legal barriers without deciding whether Bonilla was right on the underlying civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.