Bonilla
- Phyllis Hamilton
- 4:24-cv-01565
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Lloyd, Judge Hamilton dismissed multiple cases with prejudice because Bonilla showed no imminent danger and his claims faced legal bars.
Steven Wayne Bonilla and the defendants named in his multiple cases.
What happened
In Steven Wayne Bonilla v. Judge Howard Lloyd, Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against various federal and state judges. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from proceeding without fees and had not shown 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 his requests to proceed without fees were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla · No. 4:24-cv-01565
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla filed multiple complaints under 42 U.S.C. § 1983, a federal law used to bring certain civil-rights claims. The opinion describes Bonilla as a state prisoner facing a death sentence who was representing himself in these federal cases. It also states that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that challenge.
The complaints presented nearly identical claims and named various federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
Reasons for dismissal
The court said Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was facing imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several legal doctrines and decisions: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those bars.
The court also addressed impartiality. It stated that the repetitive and frivolous nature of the filings did not provide a reason to question the undersigned judge’s impartiality. The opinion notes that Bonilla named Judge Hamilton as a defendant in three of the cases and states that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Ruling and effect
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 submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.