Bonilla v. Jackson
- Phyllis Hamilton
- 4:23-cv-01854
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Leonard L. Case et al., Judge Hamilton dismissed seven civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla's seven civil-rights cases were dismissed with prejudice. The order also affected the various state judges and court employees he named as defendants by closing the cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed seven nearly identical civil-rights cases against various state judges and court employees. He sought relief related to his conviction and the handling of other cases by state and federal courts.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed an immediate danger of serious physical injury, and his complaints did not make that showing. The court also said the lawsuits would be barred even if he could proceed without paying, citing several legal doctrines and prior decisions.
The court dismissed all seven cases with prejudice, terminated the pending motions, and closed the cases. Judge Phyelis J. Hamilton also ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Jackson · No. 4:23-cv-01854
- Phyllis Hamilton
- May 26, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed seven nearly identical complaints without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against state actors. He named various state judges and court employees as defendants. The complaints sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying fees 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 did not provide a separate analysis explaining which doctrine applied to which 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 additional documents Bonilla submitted in those closed cases. The order was signed by Judge Phyelis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.