Bonilla v. Kaufman
- Phyllis Hamilton
- 4:22-cv-05356
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Steven Barnes et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases against state courts and state judges were dismissed with prejudice; the order also ended pending motions and closed the cases.
What happened
In Bonilla v. Judge Steven Barnes et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He sued state courts and judges over his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The court found that his complaints did not show such a risk. It also said that, even if he could proceed without paying, the lawsuits were barred by legal rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning the dismissals bar refiling the same cases. The clerk was ordered to end all pending motions, close the cases, and return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Kaufman · No. 4:22-cv-05356
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The opinion lists multiple related case numbers, including 22-cv-5345-PJH, 22-cv-5346-PJH, 22-cv-5347-PJH, 22-cv-5348-PJH, 22-cv-5351-PJH through 22-cv-5363-PJH, and 22-cv-5391-PJH through 22-cv-5406-PJH. The complaints presented nearly identical claims against numerous state courts and state judges. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court.
Proceeding Without Paying Filing Fees
The court addressed Bonilla's requests, or possible requests, to proceed without paying filing fees. It stated that he had been disqualified from proceeding under the prison-litigation filing-fee statute, 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time. Therefore, Bonilla could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if Bonilla's applications to proceed without paying fees were granted, the lawsuits would be barred under rules and precedents identified by the court: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain how each cited authority applied to each complaint.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. This means the dismissals bar refiling these cases. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The order does not state a separate disposition for each pending motion beyond directing that all pending motions be terminated.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.