Bonilla v. Clark
- Phyllis Hamilton
- 4:25-cv-01978
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Clark, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and the lawsuits were legally barred.
Steven Wayne Bonilla, whose listed § 1983 cases were dismissed with prejudice and closed; the defendants in those cases were affected by the termination of the lawsuits.
What happened
In Bonilla v. Clark, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under a federal civil-rights law. The opinion does not fully describe the claims because part of the text is incomplete.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he were allowed to proceed without paying, several legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also ordered the clerk to return any further documents Bonilla submits in those closed cases without filing them.
The detailed version
- Bonilla v. Clark · No. 4:25-cv-01978
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The listed cases include 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 opinion states that the complaints presented nearly identical claims, but the supplied text does not fully describe those claims.
The opinion also notes that Bonilla had a pending federal petition challenging his custody in this court, with appointed counsel, and was represented by counsel in state-court proceedings. Those matters were not decided in this order.
Reasoning
The court addressed Bonilla’s possible requests to proceed in forma pauperis, meaning without paying the required filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals may proceed without paying fees only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show imminent danger at that time.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate, claim-by-claim explanation of which cited rule applied to which case.
The court also rejected the suggestion that the repetitive and allegedly frivolous filings required the judge to step aside. It cited the rule that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge. The opinion notes that Bonilla named the judge as a defendant in two cases, although the supplied text does not fully state the allegations involving that circumstance.
Disposition
The court dismissed the listed 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 submits in those closed cases.
Practical effect stated in the order
The listed lawsuits were ended with prejudice, and the clerk was instructed not to file additional documents submitted in those closed cases. The order does not state any separate monetary award or merits judgment for or against the defendants.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.