Bonilla v. Barnes
- Phyllis Hamilton
- 4:22-cv-05345
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Barnes, Judge Hamilton dismissed the plaintiff’s multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice; the named state courts and judges were defendants in those cases.
What happened
In Bonilla v. Barnes, Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He sued state courts and judges and sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the required filing costs because his allegations did not show that he faced imminent danger of serious physical injury when he filed the cases. The court also said that, even if he could proceed that way, the lawsuits would be barred under several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, terminated the pending motions, and closed the cases. The clerk was ordered to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Barnes · No. 4:22-cv-05345
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion states that he is a condemned prisoner and has a pending federal petition challenging his detention. He also has a lawyer in state-court proceedings concerning that challenge.
The complaints presented nearly identical claims against numerous state courts and state judges. Bonilla sought relief related to his underlying conviction or to the way state and federal courts had handled his other cases.
Proceeding Without Prepaying Filing Costs
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying the filing costs, under 28 U.S.C. § 1915(g). The exception applies 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 such imminent danger.
Other Bars Identified by the Court
The court further stated that, even if Bonilla’s request to proceed without prepaying filing costs 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 did not separately analyze each of those authorities.
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.