Bonilla v. Clark
- Phyllis Hamilton
- 4:20-cv-08697
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clark, Judge Hamilton dismissed five prisoner civil-rights cases with prejudice because Bonilla lacked imminent-danger eligibility and the suits faced additional legal bars.
Steven Wayne Bonilla’s five civil-rights cases were dismissed with prejudice; the named federal and state court judges were defendants, and the clerk was directed to close the cases and return later submissions without filing.
What happened
Bonilla v. Clark involved multiple civil-rights lawsuits filed without a lawyer by Steven Wayne Bonilla, a state prisoner, against various federal and state court judges. The lawsuits sought relief related to his conviction and the handling of his other habeas petitions and court cases.
The court said Bonilla had already been barred from proceeding without paying the filing fee unless he showed that he faced an imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying the fee, the lawsuits would be barred by other legal rules concerning challenges to convictions, ongoing state proceedings, and claims against judges.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that later documents Bonilla submitted in the closed cases be returned without filing. The court also stated that the repetitive and frivolous filings did not provide a reason to question the judge’s impartiality.
The detailed version
- Bonilla v. Clark · No. 4:20-cv-08697
- Phyllis Hamilton
- Dec. 29, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed five civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various federal and state court judges as defendants. The court said the cases presented very similar claims seeking relief related to Bonilla’s underlying conviction and to the handling of his other self-represented habeas petitions and court cases. The opinion also noted that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.
Filing-fee restriction
The court addressed Bonilla’s possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without the fee may proceed only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified under that provision and that these complaints did not show imminent danger.
Other legal barriers
The court further stated that, even if a filing-fee application were granted, the lawsuits would be barred under several legal doctrines and precedents. Those included rules concerning challenges to an existing conviction, interference with ongoing state proceedings, restrictions on certain claims against federal courts, and judicial immunity or related limits on claims against judges. The opinion did not separately analyze the merits of each underlying claim.
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 repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.