Bonilla v. Delgado
- Phyllis Hamilton
- 4:22-cv-00184
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Delgado, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice, ruling Bonilla could not proceed without paying filing fees and that the suits were barred.
Steven Wayne Bonilla and his multiple related cases; the order also concerned the federal and state judges he named as defendants.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints without a lawyer against dozens of federal and state judges. He challenged his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred for other legal reasons, and it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also addressed the fact that Bonilla named her as a defendant in one case, stating that the repetitive and frivolous filings did not provide a reason to question her impartiality. The clerk was ordered to end all pending motions, close the cases, and return any further documents without filing them.
The detailed version
- Bonilla v. Delgado · No. 4:22-cv-00184
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple similar complaints under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. He filed the complaints without a lawyer and named dozens of federal and state judges as defendants. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal cases.
The order noted that Bonilla had a pending federal petition concerning his imprisonment in this court, Case No. 08-0471 YGR, with appointed counsel. It also stated that he was represented by counsel in state-court proceedings, Case No. 20-2986 PJH. The court further referred to earlier proceedings involving Bonilla, Case Nos. 11-3180 CW and 13-0951 CW, in deciding whether he could proceed without paying filing fees.
Rulings
The court held that 28 U.S.C. § 1915(g) disqualified Bonilla from proceeding in these cases without paying filing fees unless he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore ruled that Bonilla could not proceed without paying filing fees.
The court added that, even if an application to proceed without paying filing fees had been granted, the lawsuits would be barred under the legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order dismissed the cases with prejudice. It did not separately analyze the merits of Bonilla’s individual claims.
Other orders and disposition
The court addressed Bonilla’s naming of Judge Hamilton as a defendant in Case No. 22-cv-0259-PJH. It stated that the repetitive and frivolous nature of the filings did not create a basis to reasonably question the judge’s impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
The judge signed the order as Phyllis J. Hamilton, United States District Judge, on January 20, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.