Bonilla v. Clark
- Phyllis Hamilton
- 4:25-cv-01060
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clark, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice after finding no imminent danger and identifying several legal bars.
Steven Wayne Bonilla and the defendants in the listed cases. The cases were dismissed with prejudice, pending motions were terminated, the cases were closed, and further documents submitted in them were to be returned without filing.
What happened
In Bonilla v. Clark, Steven Wayne Bonilla, a condemned state prisoner, filed multiple civil-rights lawsuits without a lawyer. The complaints presented nearly identical claims. He also has a pending federal petition challenging his conviction and is represented by lawyers in related state proceedings.
The court found that Bonilla could not proceed without paying 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 those fees, several legal doctrines would bar the lawsuits. It dismissed the cases with prejudice, meaning the dismissals bar refiling these claims in these cases.
Judge Phyllis J. Hamilton also rejected any suggestion that her impartiality could reasonably be questioned. The clerk was ordered to terminate all pending motions, close the cases, and return any further documents Bonilla submits in them without filing them.
The detailed version
- Bonilla v. Clark · No. 4:25-cv-01060
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists these case numbers: 25-cv-1060-PJH, 25-cv-1061-PJH, 25-cv-1062-PJH, 25-cv-1063-PJH, 25-cv-1064-PJH, 25-cv-1186-PJH, 25-cv-1187-PJH, 25-cv-1231-PJH, 25-cv-1233-PJH, 25-cv-1235-PJH, 25-cv-1439-PJH, 25-cv-1440-PJH, 25-cv-1461-PJH, 25-cv-1721-PJH, 25-cv-1978-PJH, and 25-cv-1981-PJH. The complaints presented nearly identical claims.
The court noted that Bonilla has a pending federal petition in this district with appointed counsel and is represented by counsel in state-court proceedings. The opinion also stated that he has an extensive history of filing similar cases. A footnote said that Judge Hamilton was the fourth judge assigned Bonilla's cases and that she had issued 73 orders concerning 1,064 cases since April 30, 2020; it also stated that Bonilla had filed 962 other cases with the three other judges since 2011.
Filing-fee status and other legal bars
The court addressed Bonilla's possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if he was facing imminent danger of serious physical injury when he filed. The court found that the allegations did not show such danger. It therefore held that Bonilla could not proceed without paying the filing fee.
The court further held that, even if an application to proceed without paying the filing fee were 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 analysis of those doctrines.
Ruling
The court dismissed the cases with prejudice. The court also stated that these filings did not provide a basis to question Judge Hamilton's impartiality because of their repetitive and frivolous nature. 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 submits in the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee restrictions and other threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.