Bonilla v. Casse
- Phyllis Hamilton
- 4:22-cv-05391
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Judge Steven Barnes, Judge Hamilton dismissed multiple civil-rights cases with prejudice after barring fee-free filing and identifying additional legal barriers.
Steven Wayne Bonilla's multiple civil-rights lawsuits against numerous state courts and state judges were dismissed with prejudice; the cases were closed and further submissions were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Judge Steven Barnes et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against state courts and judges. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show that he faced an immediate risk of serious physical harm when he filed. The court also said that, even if he could proceed without paying, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Casse · No. 4:22-cv-05391
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute commonly used to challenge actions by state officials. He filed the complaints without a lawyer. The complaints were nearly identical and named numerous state courts and state judges as defendants.
Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts. The opinion also states that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that challenge.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That restriction applies unless the allegations show that the prisoner faced an immediate danger of serious physical injury when the complaint was filed.
The court found that Bonilla's allegations did not show such an immediate danger. Therefore, he could not proceed without paying the filing fee.
Other legal barriers
The court added that, even if Bonilla had been allowed to proceed without paying the filing fee, the lawsuits would still be barred under several legal doctrines and precedents. The opinion cited rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and limits on federal courts' authority to review certain state-court matters.
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 additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on September 26, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.