Bonilla v. Clay
- Phyllis Hamilton
- 4:24-cv-09492
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clay, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
What happened
In Bonilla v. Clay, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges and other officials. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines and statutes.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Clay · No. 4:24-cv-09492
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state actors. The opinion says Bonilla was representing himself in these cases. He is also a condemned prisoner with a pending federal petition challenging his imprisonment, for which he has appointed counsel, and he is represented by counsel in state-court proceedings.
The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
Court’s analysis
The court addressed whether Bonilla could proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying dismissals generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that provision.
The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without paying the filing fee. The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the doctrines or 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 resolve the underlying challenges to Bonilla’s conviction or the handling of his other cases.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion states that Bonilla named the judge as a defendant in two of the cases.
Disposition
The court 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 order was signed by Judge Phyllis J. Hamilton on January 6, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.