Bonilla v. Maier
- Phyllis Hamilton
- 4:22-cv-05361
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Barnes, Judge Hamilton dismissed the related civil-rights cases with prejudice because the complaints showed no imminent danger and were legally barred.
Steven Wayne Bonilla's multiple federal civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions in them without filing them.
What happened
In Bonilla v. Judge Steven Barnes et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against state courts and judges. He sought relief concerning his conviction and the handling of other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying the filing fees because his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also stated that, even if he had been allowed to proceed without those fees, several legal rules would bar the lawsuits.
The court dismissed all the cases with prejudice, terminated the pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Maier · No. 4:22-cv-05361
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that permits claims against state actors for certain constitutional violations. The order covers the cases listed under docket numbers 22-cv-5345-PJH through 22-cv-5406-PJH. Bonilla also had a pending federal petition challenging his detention and was represented by counsel in state-court proceedings concerning that petition.
The complaints presented nearly identical claims against numerous state courts and state judges. The order states that Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
Reasons for dismissal
The court addressed Bonilla's possible request to proceed without paying the filing fees, a status commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot proceed without paying those fees unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger. It therefore ruled that he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the order: 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 rule applied to each complaint.
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 those 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.