Bonilla v. White
- Phyllis Hamilton
- 4:24-cv-00029
- U.S. District Court · Northern District of California
- 3
In Bonilla v. White, Judge Hamilton dismissed multiple pro se civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and the suits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named federal and state judges and state courts were defendants in those cases, and the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Bonilla v. White, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against various federal and state judges and state courts. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger. It also said the lawsuits would be barred for other legal reasons even if he had been allowed to proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases. The court also rejected the argument that the judge’s impartiality could reasonably be questioned and directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. White · No. 4:24-cv-00029
- Phyllis Hamilton
- Jan. 29, 2024
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. They named various federal and state judges and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion also notes that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had already been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the required fees.
Other Legal Bars
The court further stated that, even if an application to proceed without paying fees had been granted, the lawsuits would be barred under several legal doctrines and authorities, including rules concerning challenges to criminal convictions, federal interference with certain ongoing state proceedings, claims that cannot proceed in the requested form, and limits on lawsuits against federal courts and judges. The opinion did not reach the merits of whether Bonilla’s underlying conviction or the handling of his other cases was unlawful.
Ruling
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Bonilla named Judge Hamilton as a defendant in one of the cases. Judge Hamilton concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question her impartiality and did not require her to step aside.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.