Bonilla v. Reynolds
- Phyllis Hamilton
- 4:23-cv-01853
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Reynolds, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the lawsuits were barred.
Steven Wayne Bonilla's seven civil-rights cases were dismissed with prejudice. The cases named various state judges and court employees as defendants.
What happened
In Bonilla v. Reynolds, Steven Wayne Bonilla, a state prisoner without a lawyer, filed several nearly identical civil-rights cases against state judges and court employees. He challenged his conviction and the handling of his other cases by state and federal courts.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed. The complaints did not show such danger. The court also said the lawsuits would be barred even if permission to proceed without paying were granted.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future filings in them without filing them.
The detailed version
- Bonilla v. Reynolds · No. 4:23-cv-01853
- Phyllis Hamilton
- May 26, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed seven nearly identical cases under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against state actors. The cases named various state judges and court employees as defendants. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases.
The order identifies Bonilla as proceeding without a lawyer in these civil-rights cases. It also states that he had a pending federal petition challenging his custody in the same district, with appointed counsel, and was represented by counsel in state-court proceedings.
Court's analysis
The court determined that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That provision allows a prisoner who has accumulated qualifying prior dismissals to proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without paying the filing fee. The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines or authorities identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Disposition
Judge Phyllis Hamilton ordered that the cases be dismissed with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
This was a procedural order. The court dismissed the cases based on the filing-fee restriction and other threshold bars identified in the order rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.