Bonilla v. Skillman
- Phyllis Hamilton
- 4:22-cv-05403
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Barnes, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and other legal bars applied.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return later submissions without filing them.
What happened
Bonilla v. Judge Steven Barnes et al. involved multiple nearly identical civil-rights lawsuits filed by Steven Wayne Bonilla, a condemned state prisoner, against state courts and judges. He challenged his conviction and how other cases had been handled.
Bonilla sought to proceed without paying filing fees. The court said he had already been barred from doing so unless he showed that he faced imminent danger of serious physical injury when he filed, and his complaints did not make that showing. The court also said that, even if he could proceed without paying fees, several legal rules and prior decisions barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning they could not be brought again in the same form. She also ordered the clerk to terminate pending motions, close the cases, and return any further documents Bonilla submitted without filing them.
The detailed version
- Bonilla v. Skillman · No. 4:22-cv-05403
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal law that permits certain civil-rights claims against state actors. The opinion describes Bonilla as a state prisoner who had been sentenced to death and who also had a pending federal petition challenging his custody. He represented himself in these federal cases. The defendants included numerous state courts and state judges. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
Court’s reasoning
The court addressed Bonilla’s efforts to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless he shows that he was in imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such imminent danger.
The court further stated that, even if Bonilla’s request to proceed without paying fees were granted, the lawsuits would be barred under the principles or authorities identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate detailed analysis of each authority.
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. 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.