Bonilla
- Phyllis Hamilton
- 4:24-cv-01690
- U.S. District Court · Northern District of California
- 3
Bonilla v. Judge Howard Lloyd: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not show imminent danger and the lawsuits were legally barred.
Steven Wayne Bonilla’s listed cases were dismissed with prejudice; all pending motions were terminated, the cases were closed, and further documents submitted in those closed cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple civil-rights cases without a lawyer under a federal civil-rights statute. The cases presented nearly identical claims against various federal and state judges and sought relief concerning his conviction or how other cases were handled.
Bonilla sought to proceed without paying filing fees. The court said he was barred from doing so unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the complaints did not make that showing and said the lawsuits would also be barred even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla · No. 4:24-cv-01690
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, a state prisoner described as condemned, filed multiple complaints under 42 U.S.C. § 1983, the federal statute that allows certain civil-rights claims against government actors. The complaints were filed without a lawyer and asserted nearly identical claims against various federal and state judges. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal courts. The opinion also states that he had a pending federal petition challenging his custody and was represented by counsel in state custody-related proceedings.
Filing-fee status
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) barred him from doing so unless he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the relevant time.
Other grounds for dismissal
The court further held that, even if Bonilla’s applications to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order does not provide a separate claim-by-claim analysis of those grounds.
The court also addressed impartiality. Bonilla named Judge Hamilton as a defendant in three of the cases. Judge Hamilton concluded that her impartiality could not reasonably be questioned because of the repetitive and frivolous nature of the filings. The order noted Bonilla’s extensive history of filing similar cases.
Disposition
Judge 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. Because the dismissals rested on the filing-fee restriction and other legal bars, the order did not decide the underlying validity of Bonilla’s conviction or the merits of his claims against the judges.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.