Bonilla v. Alameda County District Attorneys Office
- Phyllis Hamilton
- 4:25-cv-01186
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clark, Judge Hamilton dismissed 16 civil-rights cases with prejudice because Bonilla showed no imminent danger and the lawsuits were barred.
Steven Wayne Bonilla and the 16 cases covered by the order. The order also directed the clerk regarding pending motions, case closure, and future documents submitted in those closed cases.
What happened
In Steven Wayne Bonilla v. Linda Clark et al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. He also has a pending federal petition challenging his imprisonment, with appointed counsel, and is represented in state-court proceedings. The opinion's description of his specific allegations is incomplete in the provided text.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his allegations did not show such danger. It also said that, even if he could proceed without paying the fees, the lawsuits were barred by several legal doctrines, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases. The court also declined to recuse itself, stating that the repetitive filings did not reasonably call the judge's impartiality into question.
The detailed version
- Bonilla v. Alameda County District Attorneys Office · No. 4:25-cv-01186
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer asserting civil-rights claims under 42 U.S.C. § 1983. The order concerns 16 related 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 court described the complaints as presenting nearly identical claims. The provided opinion text is incomplete where it begins to describe whom Bonilla named and what his claims concerned. The order states that Bonilla is a condemned prisoner with a pending federal petition in this court, Case No. 08-0471 YGR, in which he has appointed counsel. It also states that he is represented by counsel in state-court proceedings, Case No. 20-2986 PJH.
Filing-fee restriction
The court considered whether Bonilla could proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot proceed without paying unless he was under imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified from proceeding without paying under that statute and that the allegations in these complaints did not show imminent danger at the time of filing.
Other grounds cited by the court
The court further stated that, even if an application to proceed without paying the filing fees were granted, the lawsuits would 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 order did not resolve the underlying claims on their merits; it relied on filing-fee restrictions and threshold legal bars.
Recusal issue
The court also addressed whether Judge Hamilton's impartiality could reasonably be questioned because of Bonilla's repetitive filings. It concluded that these were not cases requiring the judge's recusal. The order notes that Bonilla named the judge as a defendant in two of the cases, but the provided text does not describe the claims in those cases further.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order states that the judge was the fourth judge assigned cases filed by Bonilla and that the judge had issued numerous orders concerning his cases, but those statements were part of the court's discussion of the filing history rather than a decision on the merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.