Bonilla v. Clay
- Phyllis Hamilton
- 4:22-cv-01130
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clay, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not meet the imminent-danger exception and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, ending those cases and preventing further filings in them from being docketed. The order also terminated pending motions and closed the cases.
What happened
In Bonilla v. Clay, Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits without a lawyer against numerous federal and state judges. He challenged his conviction and the way other courts handled his cases.
The court said Bonilla could not proceed without paying the filing fees because he had already been barred from using the fee-waiver process and had not shown that he faced an immediate danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal rules even if his fee-waiver applications were granted.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also declined to recuse herself, explaining that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Clay · No. 4:22-cv-01130
- Phyllis Hamilton
- Mar. 14, 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 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 handling of his other cases in state and federal court.
The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee status
Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed under the fee-waiver process.
Other grounds identified by the court
The court further stated that, even if a fee-waiver application 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 opinion did not provide separate claim-by-claim analysis of those grounds.
Recusal
Bonilla named Judge Hamilton as a defendant in one of the cases. The court concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question Judge Hamilton’s impartiality. It cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
The court dismissed all of 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 further documents Bonilla submitted in those closed cases.
The order was signed by United States District Judge Phyllis J. Hamilton on March 14, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.