Bonilla v. Lake County Clerks Office
- Phyllis Hamilton
- 4:22-cv-00966
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. San Francisco County, Judge Hamilton dismissed 14 civil-rights cases with prejudice after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla and the defendants named in his 14 lawsuits were affected. The lawsuits were dismissed with prejudice and closed.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed 14 nearly identical civil-rights lawsuits against numerous federal and state judges. He challenged his conviction and the handling of his other state and federal cases.
The court ruled that Bonilla could not proceed without paying the filing fees because his complaints did not show that he faced an immediate risk of serious physical injury. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to end all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Lake County Clerks Office · No. 4:22-cv-00966
- Phyllis Hamilton
- Feb. 22, 2022
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed 14 civil-rights complaints under a federal law commonly used to sue government officials for constitutional violations. The complaints were nearly identical. They named dozens of federal and state judges and sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his confinement with an appointed lawyer and was also represented by a lawyer in state proceedings concerning his confinement.
Court’s analysis
Bonilla sought, or might have sought, permission to proceed without paying the filing fees. Federal law generally bars a prisoner who has brought three or more qualifying cases from proceeding without those fees unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when it was filed. The court ruled that these complaints did not show such a danger, so Bonilla could not proceed without paying the fees.
The court further ruled that, even if permission to proceed without paying had been granted, the lawsuits would be barred under several legal doctrines. It cited the rule that generally prevents a civil-rights lawsuit from undermining an existing conviction unless that conviction has been invalidated; the rule requiring federal courts to refrain from interfering with certain ongoing state proceedings; and additional doctrines cited through appellate decisions involving federal court and bankruptcy-court matters.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It cited the principle that, absent legitimate grounds for disqualification, a judge has a duty to decide assigned cases.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in these closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.