Bonilla v. Vacate Judgment Alameda County Court
- Phyllis Hamilton
- 4:22-cv-01548
- U.S. District Court · Northern District of California
- 2
Bonilla v. White: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were legally barred.
Steven Wayne Bonilla’s ten related civil-rights cases were dismissed with prejudice. The order also affected the named federal and state judge defendants and directed the court clerk’s handling of future filings in the closed cases.
What happened
In Bonilla v. Judge Jeffrey White, et al., Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights cases without a lawyer against numerous federal and state judges. The cases raised nearly identical challenges concerning his conviction and the handling of his other court cases.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show an immediate danger of serious physical injury when he filed. The court also stated that, even if he could proceed without fees, the lawsuits were barred by several legal rules and decisions. It dismissed all of the cases with prejudice, ended pending motions, and closed the cases.
Judge Phyllis J. Hamilton also determined that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality. She ordered the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Vacate Judgment Alameda County Court · No. 4:22-cv-01548
- Phyllis Hamilton
- Mar. 14, 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 named dozens of federal and state judges as defendants. The court said the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s possible request to proceed without paying filing fees. It held that 28 U.S.C. § 1915(g) barred him from proceeding without those fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that the complaints did not make that showing.
The court further stated that, even if Bonilla’s request to proceed without fees were granted, the lawsuits would be barred under several legal rules and decisions, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not analyze the underlying claims beyond identifying those bars.
The court also rejected the suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion stated that, absent legitimate grounds for disqualification, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those 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.