Bonilla v. Hamilton
- Phyllis Hamilton
- 4:21-cv-01875
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Hamilton, Judge Hamilton dismissed multiple civil-rights cases with prejudice, finding no imminent danger and identifying additional legal barriers.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the named federal judges, state judges, and superior courts were defendants in those cases.
What happened
In Bonilla v. Hamilton, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases against federal judges, state judges, and superior courts. The cases sought relief related to his conviction or his other habeas cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Hamilton · No. 4:21-cv-01875
- Phyllis Hamilton
- Mar. 22, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The listed case numbers were 21-cv-01638-PJH, 21-cv-01639-PJH, 21-cv-01640-PJH, 21-cv-01641-PJH, 21-cv-01681-PJH, 21-cv-01682-PJH, 21-cv-01683-PJH, 21-cv-01684-PJH, 21-cv-01685-PJH, 21-cv-01870-PJH, 21-cv-01872-PJH, 21-cv-01874-PJH, 21-cv-01875-PJH, 21-cv-01876-PJH, and 21-cv-01952-PJH.
The complaints named various federal judges, state judges, and superior courts as defendants. The court said the complaints presented very similar claims and sought relief concerning Bonilla's underlying conviction or the handling of his other self-represented habeas petitions. 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-court habeas proceedings.
Filing-fee status and legal barriers
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 that status unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger. Therefore, he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis explaining which listed rule applied to which complaint.
Recusal issue and disposition
The court also rejected the idea that Judge Hamilton's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion noted that Bonilla named Judge Hamilton as a defendant in one case, 21-cv-01875-PJH, but that complaint made no specific allegations against her; the provided text ends before completing that footnote.
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 order did not decide the underlying conviction-related questions on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.