Bonilla v. Clay
- Phyllis Hamilton
- 4:22-cv-00258
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Delgado, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because no imminent danger was shown and procedural bars applied.
Steven Wayne Bonilla's multiple § 1983 cases were dismissed with prejudice. The named federal and state judge defendants were affected by the closure of those cases. The clerk was directed to terminate pending motions and return future documents submitted in the closed cases without filing them.
What happened
In Bonilla v. Delgado, Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar civil-rights complaints without a lawyer. He sued dozens of federal and state judges and sought relief related to his conviction and how other cases had been handled.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been barred from proceeding without payment unless he showed imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also ruled that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also declined to recuse herself, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Clay · No. 4:22-cv-00258
- Phyllis Hamilton
- Jan. 20, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named dozens of federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The opinion addresses these case numbers: 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.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations in these complaints did not show imminent danger at the time of filing. As a result, Bonilla could not proceed without paying the filing fee.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately identify which doctrine applies to which case or claim.
Ruling
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not provide a basis for questioning the undersigned judge's impartiality and therefore did not require recusal. The clerk was ordered to terminate all pending motions and close the cases, and to return, without filing, any further documents Bonilla submitted in the closed cases.
Disposition
The multiple cases were dismissed with prejudice. The order did not grant or deny a separately identified motion; it directed the cases' dismissal and closure.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.