Bonilla v. Attorney General
- Phyllis Hamilton
- 4:24-cv-02243
- U.S. District Court · Northern District of California
- 2
In Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the lawsuits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the cases were closed. The defendants named in those cases were various state courts and agencies, including the State of California.
What happened
In Steven Wayne Bonilla v. State of California et al., Bonilla, a state prisoner, filed multiple similar civil-rights cases without a lawyer. He challenged his conviction and the handling of other cases by state and federal courts, naming various state courts and agencies as defendants.
The court said Bonilla could not proceed without paying filing fees because he was barred from fee-free filing unless he showed an immediate danger of serious physical injury, and his allegations did not make that showing. The court also said that, even if fee-free filing were allowed, the lawsuits were barred by several legal rules concerning challenges to criminal convictions, ongoing proceedings, and the authority of federal courts.
Judge Phyllis Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Attorney General · No. 4:24-cv-02243
- Phyllis Hamilton
- Apr. 29, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various state courts and agencies as defendants and sought relief concerning Bonilla’s underlying conviction and the handling of his other cases by state and federal courts.
The opinion states that Bonilla also had a pending federal petition challenging his detention in the same court, with appointed counsel, and was represented by counsel in state-court proceedings challenging his detention.
Fee-free filing
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying fees only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court found that Bonilla’s allegations did not show such danger. The court therefore ruled that he could not proceed without paying filing fees.
Other legal barriers
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would still 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 opinion did not decide whether Bonilla’s underlying claims were legally valid; it dismissed the cases based on these filing and threshold barriers.
Disposition
Judge Phyllis Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
The opinion additionally noted Bonilla’s extensive history of filing similar cases and stated that the undersigned judge had issued 62 orders since April 30, 2020, concerning 840 different cases filed by Bonilla. It also stated that Bonilla had filed 962 other cases with three other judges since 2011.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.