Bonilla v. San Mateo County
- Phyllis Hamilton
- 4:22-cv-00432
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Francisco County, Judge Hamilton dismissed multiple civil-rights cases with prejudice because no imminent danger was shown and other legal bars applied.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The cases named San Francisco County and numerous federal and state judges as defendants, but the order did not impose relief against those defendants.
What happened
Steven Wayne Bonilla v. San Francisco County, et al. involved multiple nearly identical civil-rights lawsuits filed by Bonilla, a state prisoner representing himself. He sued dozens of federal and state judges and sought relief connected to his conviction and the handling of his other court cases.
The court found that Bonilla’s complaints did not show he faced an immediate risk of serious physical injury when he filed them. He therefore could not proceed without paying the filing fees. The court also said that, even if he had been allowed to proceed without those fees, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. San Mateo County · No. 4:22-cv-00432
- Phyllis Hamilton
- Feb. 22, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named dozens of federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way other state and federal cases had been handled.
The order also notes that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. The opinion does not decide those other proceedings.
Filing-fee ruling and asserted barriers
To the extent Bonilla sought permission to proceed without paying the filing fee, the court applied 28 U.S.C. § 1915(g). That provision generally prevents a prisoner who has repeatedly filed qualifying cases from proceeding without prepaying the fee unless the complaint shows an imminent danger of serious physical injury. The court found that Bonilla’s allegations did not show such danger at the time of filing, so he could not proceed without paying the fee.
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, concerning certain civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, concerning federal interference with certain ongoing proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court. The court did not analyze the underlying civil-rights claims on their merits.
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 further documents Bonilla submitted in those closed cases. The order also stated that the repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality requiring recusal. 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.