Bonilla v. Lie
- Phyllis Hamilton
- 4:24-cv-00021
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Del Norte Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice, and he could not proceed without filing fees because the complaints did not show imminent danger. The cases were closed and later submissions in them were to be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple similar civil-rights lawsuits against various federal and state judges and courts. He sought relief concerning his conviction and how other cases had been handled.
The court found that Bonilla was barred from proceeding without paying the filing fees unless he showed imminent danger of serious physical injury, and his complaints did not make that showing. The court also stated that, even if he could proceed without fees, the lawsuits were barred by several legal doctrines, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Lie · No. 4:24-cv-00021
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints presented nearly identical claims and named various federal and state judges and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Inability to Proceed Without Filing Fees
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under several legal doctrines identified in the opinion, including doctrines from Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not reach the underlying merits of Bonilla’s claims.
Disposition
The court dismissed the cases 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 further documents Bonilla submitted in the closed cases.
The court separately addressed Bonilla’s naming of Judge Hamilton as a defendant in one case and concluded that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question her impartiality. Judge Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.