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N.D. Cal.Procedural orderFiled July 12, 2023

Bonilla v. U.S. District Court

Judge
Phyllis Hamilton
Docket
4:23-cv-03305
Court
U.S. District Court · Northern District of California
Pages
3
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. U.S. District Court, Judge Hamilton dismissed multiple nearly identical civil-rights cases with prejudice because Bonilla could not proceed without paying and the claims faced legal bars.

Who this affects

Steven Wayne Bonilla and the defendants in the listed cases; the cases were dismissed with prejudice and closed, and future documents submitted in them 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 lawsuits without a lawyer against various federal and state judges. He challenged his conviction or how other state and federal court cases had been handled.

The court said Bonilla had previously been barred from proceeding without paying the filing fees unless he showed an imminent danger of serious physical injury. His complaints did not make that showing. The court also said the lawsuits would be barred by several legal rules even if he were allowed to proceed without paying.

Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning those cases may not be refiled as they were. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. U.S. District Court · No. 4:23-cv-03305
Judge
Phyllis Hamilton
Date
July 12, 2023

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a statute allowing certain civil-rights claims against government actors. He filed the federal cases without a lawyer and named various federal and state judges as defendants. The complaints were nearly identical and sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts.

The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody and that he is represented by counsel in state-court proceedings concerning that petition. The order covers the case numbers listed in the caption.

Court’s reasoning

The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That rule permits a disqualified prisoner to proceed without paying only if 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.

The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court also addressed the fact that Bonilla named the presiding judge as a defendant in one case and concluded that the repetitive and frivolous nature of the filings did not create a reason to question the judge’s impartiality.

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 further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on July 12, 2023.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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