Bonilla
- Phyllis Hamilton
- 4:24-cv-01488
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Howard Lloyd, Judge Hamilton dismissed the cases with prejudice because Bonilla showed no imminent danger and his lawsuits were barred.
Steven Wayne Bonilla and the multiple related cases he filed; the order also directs the clerk to terminate pending motions, close the cases, and return future submissions in them without filing.
What happened
In Bonilla v. Judge Howard Lloyd et al., Steven Wayne Bonilla, an incarcerated person without a lawyer in these cases, filed multiple nearly identical civil-rights lawsuits against federal and state judges. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying the filing fees because he did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing proceedings, and actions against judges.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla · No. 4:24-cv-01488
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner facing a death sentence, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The complaints presented nearly identical claims against various federal and state judges. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases. The opinion also notes that he had a pending federal petition challenging his detention and was represented by counsel in state proceedings challenging his detention.
Court’s reasoning
The court explained that Bonilla had previously 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 court found that the allegations did not show such danger. The court further stated that, even if Bonilla were allowed to proceed without paying the filing fee, the lawsuits would be barred under legal rules identified in the opinion, including rules concerning challenges that would undermine a conviction, interference with ongoing state proceedings, claims that cannot proceed in federal court, and claims against judges.
The court also rejected any suggestion that Judge Hamilton should step aside. It stated that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question her impartiality. The opinion notes that Bonilla named Judge Hamilton as a defendant in three of the cases.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed 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 submits in these closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.