Bonilla v. Alameda County
- Phyllis Hamilton
- 4:22-cv-02871
- 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 lacked imminent-danger protection and faced legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the named federal and state defendants were no longer required to litigate those cases.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer. He named dozens of federal and state judges, courts, and officials, and sought relief related to his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that these complaints did not make that showing. It also said the lawsuits would be barred by other legal rules even if he were allowed to proceed without paying.
The court dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in them without filing them. Judge Phyllis J. Hamilton also declined to recuse herself, stating that the repetitive and frivolous filings did not reasonably call her impartiality into question.
The detailed version
- Bonilla v. Alameda County · No. 4:22-cv-02871
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers the cases identified by these 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 complaints presented nearly identical claims. Bonilla named dozens of federal and state judges, state courts, and federal officials. The order states that he sought relief concerning his underlying conviction or the handling of his other cases in state and federal court. It also states that he is a condemned prisoner and has a separate pending federal petition challenging his custody, with appointed counsel.
Court’s analysis
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
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 legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those rules.
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 further documents Bonilla submitted in the closed cases.
Bonilla named Judge Hamilton as a defendant in one of the cases. The court nevertheless declined to recuse, meaning to remove herself from the cases, because it found that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question her impartiality.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.