Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:21-cv-10019
- U.S. District Court · Northern District of California
- 2
Bonilla v. Marin County: Judge Hamilton dismissed multiple federal civil-rights cases with prejudice after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice; the defendants were not required to litigate the claims, and the cases were closed.
What happened
In Bonilla v. Marin County, Steven Wayne Bonilla, a state prisoner, filed multiple similar federal civil-rights cases without a lawyer. He challenged his conviction or the handling of his other cases by state and federal courts.
The court found that Bonilla had not shown an immediate danger of serious physical injury when he filed, so he could not proceed without paying the filing fees. The court also said that several legal rules would bar the lawsuits even if his fee applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:21-cv-10019
- Phyllis Hamilton
- Jan. 7, 2022
Background
Steven Wayne Bonilla, identified in the order as a state prisoner, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows claims against state actors for violating constitutional rights. The complaints sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The order states that Bonilla also had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state-court proceedings concerning that conviction.
Filing-fee determination
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under the “three strikes” rule in 28 U.S.C. § 1915(g). That rule permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show such an imminent danger. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other grounds identified by the court
The court further stated that, even if a request to proceed without paying the filing fee were granted, the lawsuits would be barred by one or more legal rules. The order cited rules concerning challenges to criminal convictions, federal interference with ongoing state proceedings, claims that cannot be brought in this type of civil-rights action, and limits on federal district-court review of certain other court proceedings. The opinion did not separately analyze each case or identify which cited rule applied to each complaint.
The court also stated that the repetitive and frivolous nature of the filings did not provide a basis to question the judge’s impartiality. A footnote explains that Bonilla named the judge as a defendant in one case, Case No. 21-cv-010031-PJH, and that the complaint made no specific allegations against the judge; the supplied opinion text ends before the footnote is complete.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in those closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.