Bonilla
- Phyllis Hamilton
- 4:24-cv-01689
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Howard Lloyd, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and identifying multiple legal barriers.
Steven Wayne Bonilla’s multiple cases were dismissed with prejudice, all pending motions were terminated, and the cases were closed; future documents submitted in those closed cases were to be returned without filing.
What happened
Steven Wayne Bonilla v. Judge Howard Lloyd et al. involves multiple nearly identical civil-rights complaints filed without a lawyer by Bonilla, whom the opinion identifies as a condemned state prisoner. He sued various federal and state judges and sought relief concerning his conviction and the handling of other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that option and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that future documents submitted in those closed cases be returned without filing. The order did not decide whether Bonilla’s underlying claims were correct.
The detailed version
- Bonilla · No. 4:24-cv-01689
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, whom the opinion identifies as a condemned state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a statute that allows certain civil-rights claims against government officials. The complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled. The opinion also states that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings challenging his custody.
Reasons for dismissal
The court addressed Bonilla’s requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that payment option may proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger, so Bonilla could not proceed without paying the fees.
The court further stated that, even if a request to proceed without paying had been granted, the lawsuits would be barred under principles and decisions cited as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain how each cited authority applied to each complaint. It also stated that Bonilla had an extensive history of filing similar cases.
Ruling and case administration
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 opinion addressed whether the judge’s impartiality might reasonably be questioned because of the repetitive and frivolous filings. It concluded that these were not cases requiring the judge’s recusal. The order was signed by Judge Phyllis J. Hamilton. It resolved the cases on filing-fee and other legal-bar grounds rather than deciding the merits of Bonilla’s challenges to his conviction or to the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.