Steven Wayne Bonilla v. Maier
- Phyllis Hamilton
- 4:22-cv-00273
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Judge Delgado, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named federal and state judge defendants were affected by the closure of those cases.
What happened
In Steven Wayne Bonilla v. Judge Delgado, et al., Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against dozens of federal and state judges. He sought relief concerning his conviction and how other state and federal cases had been handled.
The court ruled that Bonilla was barred from proceeding without paying filing fees because he had not shown an imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the cases would be barred by legal rules identified in the order, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Steven Wayne Bonilla v. Maier · No. 4:22-cv-00273
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal statute that permits certain civil-rights claims against state officials. The complaints were filed without a lawyer. Bonilla also had a pending federal petition challenging his custody in the same court with appointed counsel, and he was represented by counsel in state-court proceedings challenging his custody.
The complaints were nearly identical. They named dozens of federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
Court’s Analysis
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner with the required history of qualifying dismissals from proceeding without paying unless the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that the complaints did not show that Bonilla faced such imminent danger at the time of filing. It therefore ruled that he could not proceed without paying the filing fee. The court added that, even if an application to proceed without paying had been granted, the lawsuits would be barred under legal doctrines and authorities cited in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
The court also rejected any basis for questioning the undersigned judge’s impartiality because of the repetitive and frivolous nature of the filings. A footnote states that Bonilla named the judge as a defendant in one case but made no specific allegations against her.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.