Bonilla v. Mayfield
- Phyllis Hamilton
- 4:21-cv-02763
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and the suits were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The named defendants included federal judges, state judges, and counties. The clerk was directed to close the cases and return later documents without filing them.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights cases against federal judges, state judges, and counties. He challenged his conviction and the handling of his habeas petitions and other court cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from proceeding without fees and his complaints did not show an immediate danger of serious physical injury. The court also said the lawsuits would be barred under several legal rules even if his fee applications were granted, so it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also declined to question her impartiality based on the repetitive and frivolous filings. She ordered the clerk to end all pending motions, close the cases, and return future documents without filing them.
The detailed version
- Bonilla v. Mayfield · No. 4:21-cv-02763
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named various federal judges, state judges, and counties as defendants. The court said the complaints presented very similar claims seeking relief concerning Bonilla’s underlying conviction and the handling of his self-filed habeas petitions and other cases.
The opinion also states that Bonilla is a condemned prisoner with a pending federal habeas petition in the court, where he has appointed counsel, and that he is represented by counsel in state habeas proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals may not proceed without paying the fee unless 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 already been disqualified from proceeding without paying fees and that his allegations did not show such an imminent danger.
The court further stated that, even if Bonilla’s applications to proceed without paying fees were granted, the lawsuits would be barred under the rules or doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those bars.
The court also rejected any suggestion that its judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It cited the principle that, absent legitimate reasons for disqualification, a judge has a duty to decide cases assigned to that judge.
Ruling and case status
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.