Bonilla v. Blum
- Phyllis Hamilton
- 4:22-cv-05363
- U.S. District Court · Northern District of California
- 2
Bonilla v. Judge 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 named state courts and judges were defendants, and the clerk was directed to close the cases and return later submissions without filing.
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 lawsuits against state courts and judges. He challenged his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been disqualified from proceeding without fees, and his complaints did not show imminent danger of serious physical injury. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal rules and prior decisions.
Judge Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Blum · No. 4:22-cv-05363
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named numerous state courts and state judges as defendants and sought relief concerning Bonilla’s underlying conviction and the way his other cases had been handled by state and federal courts.
Proceeding Without Paying Fees
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. Bonilla therefore could not proceed without paying the required fees.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying fees 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 explain which specific bar applied to which complaint.
Disposition
Judge Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.