Bonilla v. Barclay
- Phyllis Hamilton
- 4:22-cv-05351
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Steven Barnes, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice after finding no imminent danger and additional legal barriers.
The order directly affected Steven Wayne Bonilla and the multiple cases he filed. It closed those cases, ended the pending motions, and directed the clerk not to file additional documents submitted in them.
What happened
In Bonilla v. Judge Steven Barnes, Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights cases against state courts and judges. He sought relief related to his conviction and to how other cases had been handled.
The court said Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the cases. The court also said the lawsuits would be barred for additional legal reasons, even if he had been allowed to proceed without paying the fee.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning the cases were closed and could not be brought again in the same form. The clerk was ordered to end all pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Barclay · No. 4:22-cv-05351
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a statute allowing claims for violations of federal rights by state actors. The opinion describes him as a condemned prisoner with a pending federal petition concerning his imprisonment. The complaints were nearly identical and named numerous state courts and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, or without prepaying the filing fee, under 28 U.S.C. § 1915(g). That restriction has an exception when the prisoner was under imminent danger of serious physical injury at the time of filing. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Additional grounds
The court further stated that, even if an application to proceed without prepaying the fee 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 separately explain which cited ground applied to which case or claim.
Disposition
The court dismissed the cases with prejudice. It also ordered 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 Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.