Bonilla v. Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-02674
- U.S. District Court · Northern District of California
- 3
Bonilla v. Marin County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and additional legal barriers.
Steven Wayne Bonilla's multiple federal civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return later submissions without filing them.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges, courts, and officials. He challenged his conviction and how other state and federal cases had been handled.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he faced imminent danger of serious physical injury. The complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and dismissed all the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. The clerk was also directed to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Court Clerk's Office · No. 4:22-cv-02674
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against people acting under state law. He represented himself. The order addresses the cases listed under case numbers 22-cv-1900-PJH, 22-cv-2674-PJH, 22-cv-2776-PJH, 22-cv-2871-PJH, 22-cv-2872-PJH, 22-cv-3247-PJH, 22-cv-3248-PJH, 22-cv-3275-PJH, 22-cv-3276-PJH, 22-cv-3318-PJH, 22-cv-3319-PJH, 22-cv-3322-PJH, 22-cv-3421-PJH, 22-cv-3422-PJH, 22-cv-3423-PJH, 22-cv-3424-PJH, 22-cv-3425-PJH, 22-cv-3445-PJH, 22-cv-3446-PJH, 22-cv-3447-PJH, 22-cv-3448-PJH, 22-cv-3449-PJH, and 22-cv-3450-PJH.
The court said the complaints presented nearly identical claims and named dozens of federal and state judges, state courts, and federal officials. According to the order, Bonilla sought relief concerning his underlying conviction or the handling of his other cases. The order also states that he had a pending federal petition challenging his custody in the same court, with appointed counsel.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That rule allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other legal barriers and disposition
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the 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 authorities.
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.
Recusal issue
The court rejected the suggestion that the judge's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings. The order states that Bonilla named the judge as a defendant in one of the cases, but the provided footnote is incomplete after stating that he presented no [text omitted or unavailable].
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.