Bonilla v. Mayfield
- Phyllis Hamilton
- 4:21-cv-00655
- U.S. District Court · Northern District of California
- 2
Bonilla v. Mayfield: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla, whose multiple lawsuits were dismissed with prejudice; the judges named as defendants; and the court clerk, who was directed to close the cases and return future submissions.
What happened
In Bonilla v. Mayfield, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against various federal and state judges. His lawsuits concerned his conviction and the handling of his prisoner petitions and other cases.
The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced an imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, legal rules would bar the lawsuits, and it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also declined to treat the repeated filings as a reason to question her impartiality. She ordered the clerk to end all pending motions, close the cases, and return future submissions without filing them.
The detailed version
- Bonilla v. Mayfield · No. 4:21-cv-00655
- Phyllis Hamilton
- Jan. 29, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order concerns case numbers 21-cv-00651-PJH, 21-cv-00652-PJH, 21-cv-00654-PJH, 21-cv-00655-PJH, 21-cv-00656-PJH, 21-cv-00657-PJH, 21-cv-00658-PJH, 21-cv-00659-PJH, 21-cv-00660-PJH, 21-cv-00661-PJH, 21-cv-00662-PJH, 21-cv-00676-PJH, and 21-cv-00677-PJH. He named various federal and state court judges as defendants. The complaints presented similar claims concerning his underlying conviction and the handling of his self-filed petitions and other cases.
The order states that Bonilla had a pending federal petition challenging his conviction and imprisonment, in which he had appointed counsel, and that he was represented by counsel in state court proceedings. The order does not describe the specific causes of action or requested relief in each individual complaint.
Filing-Fee Status
The court ruled that Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show that such danger existed at the time of filing. As a result, Bonilla could not proceed without paying the filing fee.
Other Legal Bars and Disposition
The court further stated that, even if an application to proceed without paying the filing fee 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 court therefore dismissed the cases with prejudice. The order also states that the repeated and frivolous nature of the filings did not provide a reason to question the undersigned judge’s impartiality. A footnote explains that Bonilla named the undersigned judge as a defendant in one of the cases, but that complaint made no specific allegations against her.
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. 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.