Bonilla v. Mendocino County
- Phyllis Hamilton
- 4:20-cv-05591
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Mendocino County, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the federal judges, state judges, municipalities, and other municipal and court officials named as defendants, although the opinion does not list each defendant by name.
What happened
In Bonilla v. Mendocino County, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against federal judges, state judges, municipalities, and other officials. His complaints concerned his conviction and how courts handled his petitions and other cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he faced an immediate risk of serious physical injury. The complaints did not show that kind of danger. The court also said that, even if he were allowed to proceed without paying, the lawsuits were barred by rules governing challenges to convictions and interference with ongoing court proceedings.
Judge Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return any additional filings in those closed cases without filing them.
The detailed version
- Bonilla v. Mendocino County · No. 4:20-cv-05591
- Phyllis Hamilton
- Aug. 20, 2020
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion lists fifteen case numbers, including 20-cv-02989-PJH. The defendants included various federal judges, state judges, municipalities, and other municipal and court officials. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his petitions and other cases in state and federal court.
The opinion also states that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings concerning that conviction.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has had three or more qualifying cases dismissed generally may not proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that rule and that his allegations did not show imminent danger at the time of filing.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying merits of Bonilla’s allegations.
The court also rejected any suggestion that Judge Phyllis J. Hamilton’s impartiality could reasonably be questioned, stating that there were no legitimate reasons for the judge to recuse herself.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Judge
The order was signed by Phyllis J. Hamilton, United States District Judge, on August 20, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.