Bonilla v. Maier
- Phyllis Hamilton
- 4:21-cv-02740
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Maier, Judge Hamilton dismissed Bonilla’s multiple civil-rights cases with prejudice because he could not proceed under the court’s fee-waiver rules and the suits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants included various federal judges, state judges, and counties. The clerk was directed to close the cases and return later submissions without filing them.
What happened
In Bonilla v. Maier, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases against federal judges, state judges, and counties. He made similar claims about his conviction and how courts handled his petitions and other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an imminent danger of serious physical injury, which his complaints did not show. The court also said the lawsuits would be barred for other legal reasons even if he had been allowed to proceed under the fee waiver. It dismissed the cases with prejudice.
Judge Hamilton also declined to recuse herself, meaning to step aside, based on the repetitive and frivolous filings. The clerk was ordered to terminate pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Maier · No. 4:21-cv-02740
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints named various federal judges, state judges, and counties as defendants. The court said the cases presented very similar claims concerning Bonilla’s underlying conviction and the handling of his self-represented petitions challenging his custody, as well as other court cases.
The opinion also noted that Bonilla had a pending federal petition challenging his conviction or custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning such a petition.
Fee-waiver status and dismissal
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the required filing fees, under 28 U.S.C. § 1915(g). That restriction has an exception when a prisoner shows that he was in imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if an application to proceed without paying filing fees had been granted, the lawsuits would be barred under legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and lawsuits against federal judges or courts. The court therefore dismissed the cases with prejudice.
Recusal and case closure
The court also ruled that these cases did not provide a basis to question the undersigned judge’s impartiality because of the repetitive and frivolous nature of the filings. 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.
Disposition
Judge Phyllis J. Hamilton ordered the multiple cases dismissed with prejudice and directed the clerk to close them.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.