Bonilla v. Clark
- Phyllis Hamilton
- 4:24-cv-09461
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clark, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice because Bonilla could not proceed under the filing-fee exception and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice and closed. Pending motions were terminated, and future documents submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. Clark, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various federal and state judges and other officials. He sought relief concerning his conviction and the handling of his other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been barred from using the fee-waiver process and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he had been allowed to waive the fee, the lawsuits were barred by several legal doctrines.
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 detailed version
- Bonilla v. Clark · No. 4:24-cv-09461
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner under a death sentence, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against government officials. The opinion addresses numerous related cases, including Case Nos. 24-cv-8847-PJH, 24-cv-8857-PJH, 24-cv-9025-PJH, 24-cv-9026-PJH, 24-cv-9152-PJH, 24-cv-9153-PJH, 24-cv-9175-PJH, 24-cv-9256-PJH through 24-cv-9284-PJH, 24-cv-9458-PJH through 24-cv-9461-PJH, and 24-cv-9491-PJH through 24-cv-9498-PJH.
Bonilla presented nearly identical claims in the cases. He named various federal and state judges and other officials as defendants and sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. The opinion also notes that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings challenging his conviction.
Filing-fee ruling and legal bars
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed under that fee-waiver exception.
The court further held that, even if a fee-waiver application had been granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate, claim-by-claim explanation of how each cited doctrine applied to each case.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return, without filing, any further documents Bonilla submitted in the closed cases. The court also concluded that the repetitive and allegedly frivolous filings did not provide a basis to question the undersigned judge's impartiality. Judge Phyllis J. Hamilton signed the order on January 6, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.