Bonilla v. Mayfield
- Phyllis Hamilton
- 4:24-cv-08845
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed multiple civil-rights cases with prejudice, finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The cases named various federal and state judges and other officials as defendants, and the clerk was directed to close the cases and return later submissions without filing them.
What happened
Steven Wayne Bonilla v. U.S. District Court San Francisco et al. involved multiple nearly identical lawsuits filed without a lawyer under a federal civil-rights law. Bonilla, a condemned state prisoner, sued various federal and state judges and other officials over his conviction and the handling of his cases.
The court said Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred by other legal rules and decisions.
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 submitted in those closed cases without filing them. The court also found no basis to question Judge Hamilton’s impartiality because of the repetitive filings.
The detailed version
- Bonilla v. Mayfield · No. 4:24-cv-08845
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against state actors. The complaints presented nearly identical claims and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction or the way his state and federal cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his custody in this court, with appointed counsel, under Case No. 08-0471 YGR. It also states that he was represented by counsel in state-court proceedings under Case No. 20-2986 PJH.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law permits such a prisoner to proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the time of filing. It therefore held that Bonilla could not proceed without paying the filing fee. The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules and decisions cited in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Ruling
The court dismissed the cases with prejudice. The opinion also notes that Bonilla had an extensive history of filing similar frivolous cases. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Bonilla named Judge Hamilton as a defendant in one of the cases. The court nevertheless stated that these circumstances did not provide a reasonable basis to question the judge’s impartiality because of the repetitive and frivolous nature of the filings.
Disposition
The multiple cases were dismissed with prejudice. All pending motions were terminated, the cases were closed, and later documents submitted in the closed cases were to be returned without filing.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.