Bonilla v. Reilly
- Phyllis Hamilton
- 4:20-cv-07709
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clay, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and his claims faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the defendants in those cases were therefore not required to litigate the claims further in those actions.
What happened
In Bonilla v. Clarence Don Clay, et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights cases. The cases raised similar complaints about his conviction and how state and federal courts handled his petitions and other cases.
The court said Bonilla could not proceed without paying filing fees because he had previously been barred from proceeding without them and had not shown imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits would be blocked by several legal rules. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also concluded that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality. The clerk was ordered to end all pending motions, close the cases, and return future documents from Bonilla without filing them.
The detailed version
- Bonilla v. Reilly · No. 4:20-cv-07709
- Phyllis Hamilton
- Nov. 9, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints presented very similar claims concerning his underlying conviction and the handling of his various petitions and other cases by state and federal courts. The opinion also notes that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings concerning his custody.
Filing-fee status and legal bars
The court addressed Bonilla’s requests, or possible requests, to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless he was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that provision and that his allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under several authorities, including rules concerning challenges to convictions, interference with ongoing state proceedings, and limits on federal court review of other courts’ actions. The opinion cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Ruling
The court dismissed the cases with prejudice. It also rejected the suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was directed to terminate all pending motions and close the cases, and 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 whether Bonilla’s underlying civil-rights claims were legally valid. The court resolved the matters based on the prisoner filing-fee restriction and other threshold legal bars, without deciding the underlying claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.