Bonilla v. U.S. District Court Oakland Judges
- Phyllis Hamilton
- 4:23-cv-03309
- U.S. District Court · Northern District of California
- 3
Bonilla v. U.S. District Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and required later submissions in those cases to be returned without filing.
What happened
In Bonilla v. U.S. District Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He challenged his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not make that showing. The court also said the lawsuits would be barred on other legal grounds even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. U.S. District Court Oakland Judges · No. 4:23-cv-03309
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, described in the opinion as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The cases were assigned the following numbers: 23-cv-3305-PJH, 23-cv-3306-PJH, 23-cv-3307-PJH, 23-cv-3308-PJH, 23-cv-3309-PJH, 23-cv-3329-PJH, 23-cv-3331-PJH through 23-cv-3339-PJH, and 23-cv-3340-PJH through 23-cv-3343-PJH, along with 23-cv-3355-PJH through 23-cv-3359-PJH. The complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
Filing-fee status
The court explained that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That provision permits a disqualified prisoner 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 Bonilla’s allegations did not show such danger. Therefore, he could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee 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 separately explain which cited doctrine applied to which case.
Ruling and case status
The court dismissed the cases 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 additional documents Bonilla submitted in the closed cases. The court additionally stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. A footnote noted that Bonilla named that judge as a defendant in one case but presented no reason for recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.