Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:22-cv-01546
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without fees and faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return future filings without filing them.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer while imprisoned. He named many federal and state judges and sought relief related to his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without fees, the lawsuits would be barred by other legal rules protecting convictions and limiting federal interference with ongoing or completed proceedings.
The court dismissed the cases with prejudice, ended all pending motions, and directed the clerk to close the cases and return future filings. Judge Phyllis J. Hamilton also rejected recusal based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:22-cv-01546
- Phyllis Hamilton
- Mar. 14, 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 order covers these case numbers: 22-cv-1119-PJH, 22-cv-1121-PJH, 22-cv-1122-PJH, 22-cv-1130-PJH, 22-cv-1224-PJH, 22-cv-1225-PJH, 22-cv-1546-PJH, 22-cv-1547-PJH, 22-cv-1548-PJH, and 22-cv-1549-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 way state and federal courts had handled his other cases. The order also noted that he had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee ruling
Bonilla sought, or appeared to seek, permission to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified under that provision and that his allegations did not show such an imminent danger. The court therefore ruled that he could not proceed without paying the fees.
Other legal bars
The court further ruled that, even if an application to proceed without paying fees had been granted, 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 opinion did not provide a separate merits determination of Bonilla’s underlying claims.
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 additional documents Bonilla submitted in the closed cases.
The order also addressed recusal. Although Bonilla named the judge as a defendant in one of the cases, the court stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. 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.