Bonilla v. Simmons
- Phyllis Hamilton
- 4:23-cv-06105
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge O’Farrell, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice.
Steven Wayne Bonilla’s twelve listed civil-rights cases were dismissed with prejudice. The opinion also directs the clerk to close those cases, terminate pending motions, and return later submissions without filing.
What happened
In Bonilla v. Judge O’Farrell et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against state courts and judges. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he was barred from doing so under the prisoner-litigation statute and had not shown imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, his lawsuits would be barred by several legal doctrines concerning attacks on convictions, ongoing state proceedings, and challenges to court actions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that later documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Simmons · No. 4:23-cv-06105
- Phyllis Hamilton
- Dec. 21, 2023
Background
Steven Wayne Bonilla, identified by the court as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints presented nearly identical claims and named various state courts and judges as defendants. Bonilla sought relief related to his underlying conviction and to the way state and federal courts had handled his other cases.
The opinion also states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings concerning his custody.
Court’s reasoning
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 complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the fee.
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, which concerns civil-rights claims that would improperly undermine a conviction or sentence; Younger v. Harris, which concerns federal interference with certain ongoing state proceedings; and decisions concerning challenges to federal court and bankruptcy court actions. The opinion does not separately analyze each complaint or claim.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.