Bonilla v. Contra Costa County Clerks Office
- Phyllis Hamilton
- 4:22-cv-00925
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Francisco County, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because IFP rules and other doctrines barred them.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also ended the pending motions and closed those cases.
What happened
In Bonilla v. San Francisco County, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer. He named dozens of federal and state judges and challenged his conviction or how other cases had been handled.
The court ruled that Bonilla’s allegations did not show he faced imminent danger of serious physical injury when he filed, so he could not proceed without paying the filing fees under the applicable prisoner-litigation rule. The court also said the lawsuits would be barred by other legal doctrines even if his request to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Contra Costa County Clerks Office · No. 4:22-cv-00925
- Phyllis Hamilton
- Feb. 22, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion lists these 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 presented nearly identical claims and named dozens of federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other state and federal cases. The opinion also notes that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings challenging his conviction.
Reasons for dismissal
The court considered Bonilla’s ability to proceed without paying the filing fees, a status commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such imminent danger, so he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying 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 opinion does not separately explain which doctrine applied to which claim or case.
The court also rejected any basis for the assigned judge’s recusal. It stated that the repetitive and frivolous nature of the filings did not create a circumstance in which the judge’s impartiality could reasonably be questioned, and cited the rule that judges generally have a duty to decide cases assigned to them absent legitimate grounds for recusal.
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 the closed cases. 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.