Bonilla v. Gutierrez
- Phyllis Hamilton
- 4:22-cv-05393
- 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 fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the defendants were numerous state courts and state judges named in the complaints.
What happened
In Bonilla v. Judge Steven Barnes, Steven Wayne Bonilla, a 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 state and federal cases.
The court said Bonilla could not proceed without paying the filing fees because his allegations did not show an immediate threat of serious physical injury. The court also said that, even if fee waivers were allowed, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Gutierrez · No. 4:22-cv-05393
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple lawsuits under 42 U.S.C. § 1983, a federal law that allows claims for violations of constitutional rights by state actors. He represented himself in these cases. The order states that Bonilla was a condemned prisoner and also had a pending federal petition challenging his custody, while being represented by counsel in state-court proceedings challenging his custody.
The complaints were nearly identical. They named numerous state courts and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner disqualified from proceeding without those fees may do so only by showing that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such danger.
The court then stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the principles or rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately explain how each cited authority applied to each complaint.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and legal bars without deciding the underlying claims about Bonilla’s conviction or the handling of his other cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.