Bonilla v. Clerk's Office Staff
- Phyllis Hamilton
- 4:20-cv-06811
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clay, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because no imminent-danger exception applied and other legal bars existed.
Steven Wayne Bonilla’s seven listed civil-rights cases were dismissed with prejudice, their pending motions were terminated, and the cases were closed. The order also affected the state courts, federal judges, and court officials named as defendants by ending these cases against them.
What happened
In Bonilla v. Judge Clarence Don Clay, et al., Steven Wayne Bonilla, a state prisoner representing himself, filed several civil-rights cases against state courts, federal judges, and court officials. His claims concerned his conviction and the handling of his other cases and petitions.
The court said Bonilla could not proceed without paying the filing fees unless he showed an imminent danger of serious physical injury, and his complaints did not make that showing. The court also said that, even if his fee applications were granted, legal rules would bar the lawsuits, so it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also concluded that the repetitive and frivolous filings did not provide a reason to question her impartiality. The clerk was ordered to end all pending motions, close the cases, and return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Clerk's Office Staff · No. 4:20-cv-06811
- Phyllis Hamilton
- Oct. 26, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various state courts, federal judges, and court officials as defendants. Bonilla presented similar claims in the cases and sought relief concerning his underlying conviction and the handling of his other petitions and cases by state and federal courts.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings concerning his custody.
Ruling
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without those fees may do so only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court determined that the allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying the fees were granted, the lawsuits would be barred under several legal doctrines and precedents: 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.
Other Orders
The court stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification Basis
This was a procedural order rather than a decision on the underlying civil-rights claims. The court dismissed the cases based on the prisoner filing-fee restriction and other legal barriers without deciding whether Bonilla’s substantive allegations were legally valid.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.