Bonilla v. First Appellate District Court Judges
- Phyllis Hamilton
- 4:23-cv-03333
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla showed no imminent danger and his lawsuits were barred.
Steven Wayne Bonilla's multiple civil-rights cases and the federal and state judges named as defendants were affected. The clerk was directed to close the cases, terminate pending motions, and return future submissions in those cases without filing them.
What happened
Bonilla v. U.S. District Court et al. involved multiple nearly identical complaints by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. He sued various federal and state judges over his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from fee waivers and had not shown that he faced imminent danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred by several legal rules even if his fee-waiver applications were granted.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in the closed cases without filing them. Judge Phyllis J. Hamilton signed the order.
The detailed version
- Bonilla v. First Appellate District Court Judges · No. 4:23-cv-03333
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical and named various federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts. The opinion also states that he was a condemned prisoner, had a pending federal habeas case, and was represented by counsel in state habeas proceedings.
Fee-waiver determination
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. As a result, Bonilla could not proceed under the fee-waiver procedure.
Other grounds for dismissal
The court further stated that, even if Bonilla's applications 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 does not provide a separate claim-by-claim analysis of which cited rule applied to which complaint.
Ruling and disposition
The court dismissed the cases with prejudice. It also directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The court separately rejected the contention that the judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.