Bonilla v. Sixth Appellate District Court
- Phyllis Hamilton
- 4:23-cv-03337
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court, Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the defendants in the related cases were affected. The cases were dismissed with prejudice, all pending motions were terminated, the cases were closed, and further documents Bonilla submitted in those cases were to be returned without filing.
What happened
In Bonilla v. U.S. District Court, Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He sued various federal and state judges and challenged his conviction or how other cases had been handled.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The court found that his complaints did not show such a danger. It also said that, even if he could proceed without paying, the lawsuits would be barred by rules and doctrines identified by the court, including limits on challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return, without filing, any further documents Bonilla submitted in those closed cases. The court also addressed and rejected a basis for questioning Judge Hamilton’s impartiality, including because Bonilla named her as a defendant in one case but made no legitimate showing for recusal.
The detailed version
- Bonilla v. Sixth Appellate District Court · No. 4:23-cv-03337
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims and named various federal and state judges as defendants. The opinion says Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The opinion also notes that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings challenging his custody.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding 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 faced an 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 barriers to the lawsuits
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 and authorities cited in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each authority’s application to each complaint.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court also concluded that the cases did not present a situation in which her impartiality could reasonably be questioned because of the repetitive and frivolous filings. A footnote states that Bonilla named Judge Hamilton as a defendant in one case but presented no legitimate basis for recusal.
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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.