Bonilla v. Clay
- Phyllis Hamilton
- 4:22-cv-00666
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Francisco County, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice and barred him from proceeding without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice; the order also directed the clerk to close the cases and return later submissions without filing.
What happened
In Bonilla v. San Francisco County, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against dozens of federal and state judges. He challenged his conviction and how other state and federal cases were handled.
The court found that Bonilla’s complaints did not show he faced an immediate danger of serious physical injury when he filed them. It therefore ruled that he could not proceed without paying the filing fee. The court also said the lawsuits would be barred for additional legal reasons, including rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
The court dismissed all of the cases with prejudice, directed the clerk to end pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing. Judge Phyllis J. Hamilton also declined to recuse herself, finding no reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Clay · No. 4:22-cv-00666
- 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 order covers the following 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 raised nearly identical claims and named dozens of federal and state judges as defendants. The order says Bonilla sought relief concerning his underlying conviction or the handling of his other state and federal cases. It also notes that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Ruling on filing fees and the cases
Bonilla sought, or could have sought, permission to proceed without paying filing fees. The court applied the federal rule that generally bars a prisoner with qualifying prior cases from proceeding without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court found that these complaints did not show such danger, so Bonilla could not proceed without paying the filing fee.
The court further stated that, even if permission to proceed without paying had been granted, the lawsuits would be barred under the legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those legal principles.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases.
Recusal
The court separately addressed whether the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It concluded that these were not cases requiring recusal and cited the principle that, absent legitimate reasons for recusal, a judge has a duty to hear assigned cases.
Disposition
The cases were dismissed with prejudice. The order also barred Bonilla from proceeding without paying filing fees in these cases, terminated pending motions, closed the cases, and addressed recusal as described above.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.