Bonilla v. Monterey County
- Phyllis Hamilton
- 4:22-cv-00433
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Francisco County, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and several legal bars.
Steven Wayne Bonilla, the defendants named in the multiple cases, and the pending cases and motions addressed by the order.
What happened
In Bonilla v. San Francisco County, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases against many federal and state judges. He challenged his conviction and how other state and federal cases had been handled.
The court found that his complaints did not show he faced imminent danger of serious physical injury when he filed them. The court also said that, even if he could proceed without paying filing fees, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and actions against judges.
The court dismissed all of the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return later filings without filing them. Judge Phyllis J. Hamilton also declined to recuse herself, stating that the repetitive and frivolous filings did not reasonably call her impartiality into question.
The detailed version
- Bonilla v. Monterey County · No. 4:22-cv-00433
- Phyllis Hamilton
- Feb. 22, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state actors. The opinion lists multiple related case numbers: 22-cv-0275-PJH, 22-cv-0381-PJH, 22-cv-0432-PJH, 22-cv-0433-PJH, 22-cv-0666-PJH, 22-cv-0883-PJH, 22-cv-0885-PJH, 22-cv-0886-PJH, 22-cv-0888-PJH, 22-cv-0925-PJH, 22-cv-0966-PJH, 22-cv-0967-PJH, 22-cv-0968-PJH, and 22-cv-0969-PJH.
The complaints were filed without a lawyer and presented nearly identical claims. Bonilla named dozens of federal and state judges as defendants. The opinion says he sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. It also notes that he had a pending federal petition with appointed counsel and was represented by counsel in state court proceedings.
Court’s analysis
The court addressed Bonilla’s possible requests to proceed without paying filing fees. Under the federal filing-fee statute, a prisoner who has accumulated certain prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show imminent danger at that time.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several legal doctrines and authorities cited in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and suits against judges.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases.
The court also considered whether the judge’s impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. It concluded that these were not cases requiring recusal. The order was signed by Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.