Bonilla v. Freeman
- Phyllis Hamilton
- 4:22-cv-02872
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and the suits were otherwise barred.
Steven Wayne Bonilla’s 23 related civil-rights cases were dismissed with prejudice, affecting his claims against the federal and state judges, courts, and officials he named as defendants.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer. He challenged his underlying conviction and the handling of his other cases, naming federal and state judges, courts, and officials as defendants.
The court ruled that Bonilla could not proceed without prepaying filing fees because he had already been disqualified from that status and did not show an immediate danger of serious physical injury when he filed. The court also said the lawsuits would be barred under several legal rules even if his applications had been granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Freeman · No. 4:22-cv-02872
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The opinion concerns 23 related case numbers, including 22-cv-1900-PJH. Bonilla also had a pending federal petition in the same court concerning his imprisonment, with appointed counsel.
The complaints presented nearly identical claims. Bonilla named dozens of federal and state judges, various state courts, and federal officials. According to the opinion, he sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.
Court’s analysis
The court addressed Bonilla’s ability to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without prepaying fees only if 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 previously been disqualified and that the allegations in these complaints did not show such an imminent danger.
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion therefore did not allow the cases to proceed.
The court also declined to recuse, or remove, the assigned judge based on the repetitive and frivolous nature of the filings. The opinion states that Bonilla named the undersigned judge as a defendant in one case, but the footnote is incomplete in the provided text. The court cited the principle that, absent legitimate reasons for recusal, a judge has a duty to hear assigned cases.
Disposition
The court dismissed the cases with prejudice. It ordered 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 the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.