Bonilla v. Clay
- Phyllis Hamilton
- 4:22-cv-00883
- U.S. District Court · Northern District of California
- 2
Bonilla v. San Francisco County: Judge Hamilton dismissed multiple civil-rights cases with prejudice, finding no imminent danger and citing several legal bars.
Steven Wayne Bonilla and the defendants named in his multiple civil-rights cases, including San Francisco County and numerous federal and state judges.
What happened
In Steven Wayne Bonilla v. San Francisco County, et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against dozens of federal and state judges. He challenged his conviction or how his other cases had been handled.
The court said Bonilla had not shown that he faced an immediate danger of serious physical injury when he filed the cases. As a result, he could not proceed without paying filing fees up front. The court also said the lawsuits would be barred by several legal rules even if permission to proceed that way were granted, and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton stated that the repetitive and frivolous filings did not provide a reason to question her impartiality. The clerk was directed to end all pending motions, close the cases, and return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Clay · No. 4:22-cv-00883
- Phyllis Hamilton
- Feb. 22, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state officials. The complaints presented nearly identical claims and named dozens of federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the way his state and federal cases had been handled.
The opinion also states that Bonilla had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings. The court referred to those proceedings but did not decide them in this order.
Rulings
The court addressed Bonilla’s possible requests to proceed without paying filing fees up front. Under the federal prisoner statute, a prisoner who has repeatedly filed cases dismissed as frivolous or otherwise disqualified generally may not proceed that way unless the complaint shows an imminent danger of serious physical injury. The court held that the complaints did not show such danger at the time they were filed.
The court further stated that, even if an application to proceed without paying filing fees up front were granted, the lawsuits would be barred under the rules or doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice. The opinion does not analyze the underlying civil-rights claims on their merits.
Impartiality and Case Administration
Judge Phyllis J. Hamilton stated that these were not cases in which her impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. Citing Ninth Circuit authority, she said that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.