Bonilla v. O'Farrell
- Phyllis Hamilton
- 4:23-cv-06085
- U.S. District Court · Northern District of California
- 2
In Bonilla v. O’Farrell, Judge Hamilton dismissed multiple federal civil-rights cases with prejudice, ruling Bonilla could not proceed without paying filing fees and the lawsuits were barred.
Steven Wayne Bonilla’s twelve related civil-rights cases were dismissed with prejudice. The order also affected any pending motions and later documents submitted in those closed cases.
What happened
In Bonilla v. O’Farrell, Steven Wayne Bonilla, a condemned state prisoner filing without a lawyer, brought multiple nearly identical federal civil-rights complaints under federal law. He named various state courts and judges and sought relief concerning his conviction or the handling of his other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying filing fees because he was disqualified under a federal law that allows such filings only when a prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that his allegations did not show that danger. It also stated that, even if he could proceed without paying fees, the lawsuits would be barred under several legal doctrines and earlier court decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning the order used that term to bar refiling these cases. The clerk was directed to end all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. O'Farrell · No. 4:23-cv-06085
- Phyllis Hamilton
- Dec. 21, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute used to bring certain civil-rights claims. The complaints presented nearly identical claims and named various state courts and judges as defendants. Bonilla sought relief related to his underlying conviction or to the way state and federal courts had handled his other cases.
The opinion also states that Bonilla had a pending federal petition concerning his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings concerning his custody. The court did not resolve those other proceedings in this order.
Reasons for dismissal
The court addressed Bonilla’s request, to the extent he sought to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla was disqualified from proceeding without prepaying fees 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 imminent danger at the time of filing.
The court further stated that, even if an application to proceed without prepaying fees 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 provide a separate claim-by-claim analysis of those grounds.
Disposition
The court ordered that the cases be dismissed with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on December 21, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.