Bonilla v. Warden - Vacaville Medical Facility
- Phyllis Hamilton
- 4:23-cv-06432
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge O’Farrell, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and legal bars applied.
Steven Wayne Bonilla and the defendants named in his multiple civil-rights complaints.
What happened
In Steven Wayne Bonilla v. Judge O’Farrell et al., Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against state courts and judges. He challenged his conviction and the handling of other cases by state and federal courts.
The court said Bonilla could not proceed without paying the filing fee because he did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred even if he were allowed to proceed without paying.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton issued the order.
The detailed version
- Bonilla v. Warden - Vacaville Medical Facility · No. 4:23-cv-06432
- Phyllis Hamilton
- Dec. 21, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, the federal statute used for certain civil-rights claims against state actors. The complaints were nearly identical. They named various state courts and judges and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The order also notes that Bonilla is a condemned prisoner with a pending federal petition concerning his custody in the same court, where he has appointed counsel. It further states that he is represented by counsel in state-court proceedings concerning that petition.
Court’s analysis
The court addressed Bonilla’s effort to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the filing fee.
The court then stated that, even if an application to proceed without paying had been granted, the lawsuits would still be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order does not separately explain how each cited decision applies to each complaint.
Disposition
The court dismissed the cases with prejudice. The clerk was directed 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 December 21, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.