Bonilla v. Clay
- Phyllis Hamilton
- 4:22-cv-00277
- U.S. District Court · Northern District of California
- 2
Bonilla v. Judge Delgado: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the cases were closed. The order also affected any future filings Bonilla attempted to submit in those closed cases, which the clerk was directed to return without filing.
What happened
In Bonilla v. Judge Delgado, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against many federal and state judges. He challenged his conviction or how other courts handled his cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed imminent danger of serious physical injury, and his complaints did not show that danger. The court also said the lawsuits would be barred even if he could proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future filings without filing them.
The detailed version
- Bonilla v. Clay · No. 4:22-cv-00277
- 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, a federal law allowing claims against state actors for violations of federal rights. The complaints were filed without a lawyer and presented nearly identical claims. Bonilla named dozens of federal and state judges as defendants and sought relief concerning his underlying conviction or the handling of his other cases. The opinion lists multiple case numbers, including 22-cv-0184-PJH, 22-cv-0185-PJH, 22-cv-0188-PJH, 22-cv-0189-PJH, 22-cv-0258-PJH, 22-cv-0259-PJH, 22-cv-0260-PJH, 22-cv-0268-PJH, 22-cv-0269-PJH, 22-cv-0270-PJH, 22-cv-0271-PJH, 22-cv-0272-PJH, 22-cv-0273-PJH, 22-cv-0274-PJH, 22-cv-0276-PJH, 22-cv-0277-PJH, and 22-cv-0278-PJH.
The opinion noted that Bonilla had a pending federal petition concerning his conviction with appointed counsel and was represented by counsel in state-court proceedings concerning his conviction.
Court’s Analysis
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), which limits that privilege for a prisoner who has repeatedly filed qualifying actions. The exception applies when 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 imminent danger at that time.
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules 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 separately explain which cited rule applied to which case.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. A footnote states that Bonilla named the judge as a defendant in one case but made no specific allegations against the judge; the excerpted footnote ends before completing that discussion.
Ruling and Effect
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. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in those closed cases.
The opinion does not identify a defendant named Clay; its caption identifies the defendants as “JUDGE DELGADO, et. al.”
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.