Bonilla v. Simmons
- Phyllis Hamilton
- 4:23-cv-02747
- U.S. District Court · Northern District of California
- 2
In Bonilla v. United States District Court et al., Judge Hamilton dismissed seven civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla, who filed seven self-represented civil-rights cases concerning his conviction and the handling of his other cases; the named defendants were various federal and state courts.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed seven nearly identical civil-rights cases against various federal and state courts. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla was barred from proceeding without paying the filing fees because his complaints did not show imminent danger of serious physical injury. The court also stated that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines. It dismissed all seven cases with prejudice, closed them, and directed the clerk to return future filings in those cases without filing them.
Judge Phyllis J. Hamilton issued the order on June 27, 2023. The order also directed the clerk to terminate all pending motions.
The detailed version
- Bonilla v. Simmons · No. 4:23-cv-02747
- Phyllis Hamilton
- June 27, 2023
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order states that he is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel, and that he is also represented by counsel in state-court proceedings.
The complaints presented nearly identical claims. Bonilla named various federal and state courts as defendants and sought relief concerning his underlying conviction or the way his other cases had been handled.
Court’s analysis
The court explained that Bonilla had been disqualified from proceeding without paying the filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order does not provide separate analysis of each doctrine or explain which doctrine applies to which claim.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submits in those closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.