Bonilla v. Marin County
- Phyllis Hamilton
- 4:22-cv-00272
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Delgado, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. He could not proceed without paying filing fees because the court found no imminent danger of serious physical injury, and the clerk was ordered to close the cases and return later submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against dozens of federal and state judges. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he showed an imminent danger of serious physical injury. The court found that his complaints did not show such danger when they were filed.
The court also said that, even if Bonilla could proceed without paying fees, legal doctrines would bar the lawsuits. Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to close them and end all pending motions, and directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Marin County · No. 4:22-cv-00272
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical and named dozens of federal and state judges as defendants. The court said Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his confinement in the same court, where he had appointed counsel, and that he was also represented by counsel in state-court proceedings challenging his confinement.
Filing-fee status
Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner with qualifying prior cases from proceeding without fees unless 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 in these complaints did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fees.
Other barriers and disposition
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim explanation of how each doctrine applied.
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 court rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The opinion noted that Bonilla named Judge Hamilton as a defendant in one case but made no specific allegations against her. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.