Bonilla v. The Alameda County District Attorney's Office Civil Conspiracy and…
Bonilla v. The Alameda County District Attorney's Office Civil Conspiracy and its Memebers
- Phyllis Hamilton
- 4:20-cv-04792
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Defendants, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits faced legal barriers.
Steven Wayne Bonilla's multiple self-represented civil-rights cases were dismissed with prejudice; the court also ordered the clerk to close the cases and return future submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits under a federal law allowing claims against government officials. The cases named federal judges, state judges, municipalities, and other officials, and sought relief related to his conviction and court proceedings.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from using the fee-waiver process, and his allegations did not show an immediate danger of serious physical injury. The court also said that, even if he were allowed to proceed without fees, legal doctrines would bar the lawsuits.
In Bonilla v. Defendants, Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning the dismissals were final. The clerk was ordered to end all pending motions, close the cases, and return future submissions without filing them.
The detailed version
- Bonilla v. The Alameda County District Attorney's Office Civil Conspiracy and… · No. 4:20-cv-04792
- Phyllis Hamilton
- Aug. 20, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law used to seek relief for alleged violations of constitutional rights by state or local officials. The court identified the cases by these docket numbers: 20-cv-02989-PJH, 20-cv-04791-PJH, 20-cv-04792-PJH, 20-cv-05250-PJH, 20-cv-05252-PJH, 20-cv-05591-PJH, 20-cv-05598-PJH, 20-cv-05600-PJH, 20-cv-05603-PJH, 20-cv-05652-PJH, 20-cv-05701-PJH, 20-cv-05774-PJH, 20-cv-05776-PJH, 20-cv-05827-PJH, and 20-cv-05847-PJH.
The complaints named various federal judges, state judges, municipalities, and other municipal and court officials. The court said the complaints presented similar claims seeking relief concerning Bonilla's underlying conviction and the handling of his self-represented petitions and other cases. The opinion also stated that Bonilla had a pending federal petition in this court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee issue
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was in immediate danger of serious physical injury when he filed his complaints. The court cited two earlier proceedings in stating that he had been disqualified under that provision. It found that the allegations did not show such danger at the time of filing.
Other grounds identified by the court
The court further stated that, even if a fee-waiver application were granted, 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 analysis of those rules.
The court also stated that these were not cases in which the presiding judge's impartiality could reasonably be questioned. It cited a decision explaining that, absent legitimate reasons for recusal, a judge has a duty to hear assigned cases.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.