Bonilla v. Marin County
- Phyllis Hamilton
- 4:22-cv-00271
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Delgado, Judge Hamilton dismissed multiple cases with prejudice because Bonilla showed no imminent danger and faced legal barriers.
Steven Wayne Bonilla and the multiple civil-rights cases covered by the order; the order also directed the clerk regarding future filings in those closed cases.
What happened
In Bonilla v. Delgado, et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against numerous federal and state judges. He challenged his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The court found that his complaints did not make that showing. It also said that, even if he could proceed without paying fees, several legal doctrines would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Marin County · No. 4:22-cv-00271
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla, identified by the court as a state prisoner, 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. They sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled.
The court also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings challenging his custody.
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 been disqualified from that status may proceed without paying fees only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore concluded that he could not proceed without paying filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred by one or more legal doctrines identified in the order, including doctrines concerning attacks on criminal convictions, interference with ongoing state proceedings, challenges to other federal court proceedings, and challenges to bankruptcy-court proceedings. The court did not decide the underlying validity of Bonilla’s conviction or the merits of his allegations against the judges.
The court also rejected the apparent basis for recusal. It stated that the repetitive and frivolous nature of the filings did not, by itself, create a reasonable question about the undersigned judge’s impartiality. A footnote states that Bonilla named the judge as a defendant in one case but made no specific allegations against that judge; the text of that footnote is incomplete in the provided opinion.
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 further 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.