Bonilla v. Anthony
- Phyllis Hamilton
- 4:22-cv-01122
- U.S. District Court · Northern District of California
- 2
Steven Wayne Bonilla v. Judge Jeffrey White: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the named federal and state judge defendants by closing the cases and ending the pending motions.
What happened
In Steven Wayne Bonilla v. Judge Jeffrey White, Bonilla, a state prisoner, filed several nearly identical civil-rights cases without a lawyer. He named dozens of federal and state judges and sought relief concerning his conviction or how other courts handled his cases.
The court said Bonilla could not proceed without paying the filing fees because he was disqualified from that process and had not shown an immediate danger of serious physical injury when he filed. The court also said the lawsuits would be barred by other legal rules even if his request to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further filings in them without filing them.
The detailed version
- Bonilla v. Anthony · No. 4:22-cv-01122
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. He proceeded without a lawyer in these cases. The complaints named dozens of federal and state judges as defendants and sought relief related to Bonilla’s underlying conviction or the handling of his other state and federal court cases.
The order 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 proceedings challenging his custody.
Reasons for dismissal
The court addressed Bonilla’s requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), the court said he had been disqualified from using that procedure unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fees.
The court further stated that, even if it granted Bonilla’s requests to proceed without paying, the lawsuits would be barred under the legal rules 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 rules.
The court also rejected any concern that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in one of the cases and cited the rule that, absent legitimate grounds for recusal, a judge generally has a duty to decide cases assigned to that judge.
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 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.