Bonilla v. Hamilton
- Phyllis Hamilton
- 4:24-cv-01711
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Howard Lloyd et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice, and pending motions were terminated. The clerk was instructed to close the cases and return future submissions in them without filing them.
What happened
In Bonilla v. Judge Howard Lloyd et al., Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits under a federal law that permits claims against government officials. He named various federal and state judges and sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he had qualified to proceed without paying, the lawsuits were barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents Bonilla submits in those closed cases without filing them.
The detailed version
- Bonilla v. Hamilton · No. 4:24-cv-01711
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983. 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 his other state and federal cases had been handled. The opinion covers the case numbers listed in the caption, including 24-cv-1206-PJH, 24-cv-1211-PJH, 24-cv-1486-PJH, 24-cv-1488-PJH, 24-cv-1490-PJH, 24-cv-1491-PJH, 24-cv-1492-PJH, 24-cv-1493-PJH, 24-cv-1494-PJH, 24-cv-1536-PJH, 24-cv-1565-PJH, 24-cv-1566-PJH, 24-cv-1567-PJH, 24-cv-1568-PJH, 24-cv-1569-PJH, 24-cv-1570-PJH, 24-cv-1571-PJH, 24-cv-1572-PJH, 24-cv-1574-PJH, 24-cv-1575-PJH, 24-cv-1689-PJH, 24-cv-1690-PJH, 24-cv-1709-PJH, 24-cv-1710-PJH, and 24-cv-1711-PJH, as well as 24-cv-1854-PJH.
Proceeding Without Paying 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 showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore concluded that Bonilla could not proceed without paying the fees.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim explanation of which rule applied to which complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submits in the closed cases.
The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. Judge Hamilton signed the order on March 27, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.