Bonilla v. San Francisco County
- Phyllis Hamilton
- 4:22-cv-00275
- 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 Bonilla showed no imminent danger and the suits faced other legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The clerk was directed to close the cases, terminate pending motions, and return without filing any further documents Bonilla submitted in them.
What happened
Bonilla v. San Francisco County involved multiple complaints by Steven Wayne Bonilla, a state prisoner, against dozens of federal and state judges. The complaints raised nearly identical issues about his conviction and how other state and federal court cases were handled.
The court ruled that the complaints did not show Bonilla faced imminent danger of serious physical injury when he filed them, so he could not proceed without paying filing fees under the applicable rule. The court also said that, even if his requests to proceed without paying fees were granted, the lawsuits would be barred under several cited legal decisions. The cases were dismissed with prejudice.
Judge Phyllis J. Hamilton also found that the repetitive and allegedly frivolous filings did not provide a basis to question her impartiality. The clerk was ordered to end all pending motions, close the cases, and return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. San Francisco County · No. 4:22-cv-00275
- Phyllis Hamilton
- Feb. 22, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. 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 handling of his other cases. The opinion also notes that Bonilla had a pending federal petition involving his conviction, with appointed counsel, and was represented by counsel in state proceedings concerning that petition.
Proceeding Without Paying Filing Fees
To the extent Bonilla sought permission to proceed without paying filing fees, the court applied 28 U.S.C. § 1915(g). The court found that the complaints did not show he was in imminent danger of serious physical injury when he filed them. The court therefore ruled that he could not proceed under that provision.
Disposition
The court further stated that, even if a request to proceed without paying filing fees 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 court accordingly dismissed the cases with prejudice. The opinion does not separately describe a different disposition for individual claims within the cases.
Impartiality and Case Closure
The court found that the repetitive and frivolous nature of the filings did not create a situation in which the undersigned judge's impartiality might reasonably be questioned. Judge Phyllis J. Hamilton directed the clerk 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.