Bonilla v. Contra Costa County
- Phyllis Hamilton
- 4:20-cv-02982
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Contra Costa County, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and independent legal bars.
Steven Wayne Bonilla and the multiple civil-rights cases he filed; the cases were dismissed with prejudice and closed.
What happened
In Bonilla v. Contra Costa County, Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights lawsuits without a lawyer. He sued federal and state judges, municipalities, and other government and court officials, challenging his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he showed that he faced an immediate danger of serious physical injury. The court found that his allegations did not show such danger when he filed the complaints. It also stated that, even if he had been allowed to proceed without fees, legal rules independently barred the lawsuits.
The court dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future filings in those 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. Contra Costa County · No. 4:20-cv-02982
- Phyllis Hamilton
- July 14, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner sentenced to death, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The related case numbers were 20-cv-02982-PJH, 20-cv-02994-PJH, 20-cv-02998-PJH, 20-cv-03167-PJH, 20-cv-03351-PJH, 20-cv-03354-PJH, 20-cv-03396-PJH, 20-cv-03404-PJH, 20-cv-04314-PJH, 20-cv-04462-PJH, and 20-cv-04524-PJH.
Bonilla named various federal judges, state judges, municipalities, and other municipal and court officials as defendants. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction and the handling of his other petitions and cases. The opinion also noted that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying fees only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court found that Bonilla’s allegations did not show imminent danger at the relevant time. It therefore ruled that he could not proceed without paying the filing fees.
Other Legal Bars
The court further stated that, even if Bonilla had been allowed to proceed without paying filing fees, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim explanation of how each cited rule applied to each complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk 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 stated that the cases did not present a situation in which the undersigned judge’s impartiality could reasonably be questioned. The order was signed by United States District Judge Phyllis J. Hamilton on July 14, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.