Bonilla v. Ortez
- Phyllis Hamilton
- 4:22-cv-05357
- 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 the lawsuits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. He could not proceed without paying the filing fees because the court found no imminent danger of serious physical injury, and the court said the lawsuits would also be barred under several legal doctrines.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights cases without a lawyer against state courts and state judges. He sought relief concerning his conviction and the handling of his other cases in state and federal courts.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed an imminent danger of serious physical injury, and his complaints did not make that showing. The court also said the lawsuits would be barred under several legal doctrines, including rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate 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. Ortez · No. 4:22-cv-05357
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases included docket numbers 22-cv-5345-PJH, 22-cv-5346-PJH, 22-cv-5347-PJH, 22-cv-5348-PJH, 22-cv-5351-PJH through 22-cv-5363-PJH, and 22-cv-5391-PJH through 22-cv-5406-PJH as listed in the order. The complaints were nearly identical. Bonilla named numerous state courts and state judges as defendants and sought relief related to his underlying conviction and the handling of his other cases in state and federal courts.
The order also states that Bonilla had a pending federal petition challenging his imprisonment and was represented by counsel in state-court proceedings concerning such a challenge.
Filing-fee status and legal barriers
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner with qualifying prior cases from proceeding without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger, so he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under several doctrines and precedents: Heck v. Humphrey, concerning certain civil-rights claims that would undermine a conviction; Younger v. Harris, concerning federal interference with ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.