Bonilla v. Court Clerk Supervisor
- Phyllis Hamilton
- 4:20-cv-04317
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Court Clerk Supervisor, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims faced legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also affected the federal judges, state judges, municipalities, and other court officials he named as defendants, as well as any pending motions and later documents in those closed cases.
What happened
In Bonilla v. Court Clerk Supervisor, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against federal and state judges, municipalities, and other court officials. He challenged matters involving his conviction and the handling of his other cases and habeas petitions.
The court found that Bonilla was barred from proceeding without paying filing fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed the complaints. The court also said that, even if he were allowed to proceed without fees, the lawsuits would be barred under several legal rules and prior decisions.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in the closed cases without filing them. Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned.
The detailed version
- Bonilla v. Court Clerk Supervisor · No. 4:20-cv-04317
- Phyllis Hamilton
- July 6, 2020
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 people acting under state law. The complaints were filed without a lawyer. The defendants included various federal judges, state judges, municipalities, and other court officials. The opinion says that Bonilla raised very similar claims in the cases, seeking relief related to his underlying conviction and to the way state and federal courts handled his other cases and petitions.
The opinion also states that Bonilla had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state-court proceedings involving such a petition.
Proceeding Without Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That restriction applies unless the prisoner shows that he was facing an imminent danger of serious physical injury when the complaint was filed. The court found that the allegations in these complaints did not show such danger. Accordingly, Bonilla could not proceed without paying the filing fee.
Other Grounds Cited by the Court
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the principles 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 grounds.
Ruling
The court dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also concluded that these were not cases in which the assigned judge’s impartiality could reasonably be questioned. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.