Bonilla v. Clay
- Phyllis Hamilton
- 4:20-cv-03167
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clay, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying fees and the claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions without filing them.
What happened
Bonilla v. Clay involved multiple civil-rights lawsuits filed without a lawyer by Steven Wayne Bonilla, a state prisoner. He sued federal judges, state judges, municipalities, and other court and municipal officials over his conviction and the handling of his other legal proceedings.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status and had not shown that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also concluded that there was no proper basis to question her impartiality. The clerk was ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Clay · No. 4:20-cv-03167
- Phyllis Hamilton
- July 14, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing claims against state actors for certain constitutional violations. The complaints named various federal judges, state judges, municipalities, and other municipal and court officials. The court said the cases presented very similar claims concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court.
The opinion also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. The opinion did not decide the underlying validity of his conviction or the merits of the claims in these civil-rights cases.
Rulings
The court addressed Bonilla’s requests, to the extent made, to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court determined that Bonilla had been disqualified from proceeding without paying under that provision and that the allegations did not show such an immediate danger at the time of filing.
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under rules and doctrines identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
The court also concluded that these cases were not matters in which its impartiality could reasonably be questioned. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases. 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.