Bonilla v. Clay
- Phyllis Hamilton
- 4:20-cv-04304
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clay, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla and the defendants in the listed civil-rights cases; the cases were dismissed with prejudice and Bonilla could not proceed without prepaying filing fees based on the court’s ruling.
What happened
In Bonilla v. Clay, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed several civil-rights lawsuits against federal judges, state judges, municipalities, and other court officials. He raised similar claims about his conviction and how his other cases and petitions had been handled.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The allegations did not show that risk. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also said its impartiality could not reasonably be questioned. Judge Phyllis J. Hamilton ordered the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Clay · No. 4:20-cv-04304
- Phyllis Hamilton
- July 6, 2020
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 multiple case numbers, including 20-cv-04301-PJH and related cases. Bonilla had a pending federal petition challenging his detention or conviction in the same court, where he had appointed counsel, and he was also represented by counsel in state-court proceedings.
The complaints named various federal judges, state judges, municipalities, and other court officials as defendants. The court said the cases presented very similar claims seeking relief concerning Bonilla’s underlying conviction or the handling of his petitions and other cases by state and federal courts.
Filing-fee status and legal barriers
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying filing fees, under 28 U.S.C. § 1915(g). That restriction has an exception when a prisoner is under imminent danger of serious physical injury at the time of filing. The court found that the allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without prepaying 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 opinion does not provide a separate claim-by-claim analysis explaining which cited rule applies to which lawsuit.
Ruling
The court dismissed the cases with prejudice. It also stated that this was not a situation in which the judge’s impartiality might reasonably be questioned. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Disposition
The cases were dismissed with prejudice, and the pending motions were terminated. The order was signed by United States District Judge Phyllis J. Hamilton on July 6, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.