Bonilla v. Federal Bureau of Investigation
- Phyllis Hamilton
- 4:22-cv-02776
- 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 other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The order also terminated pending motions and directed the clerk to return future filings in those closed cases without filing them.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against dozens of federal and state judges, courts, and federal officials. He sought relief related to his conviction and the handling of his other cases.
Bonilla was a state prisoner proceeding without a lawyer. The court said he was barred from proceeding without paying filing fees unless he showed an imminent danger of serious physical injury, and his complaints did not make that showing. The court also said the lawsuits were barred by other legal rules.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also stated that her impartiality could not reasonably be questioned because of the repetitive and frivolous filings, even though Bonilla named her as a defendant in one case.
The detailed version
- Bonilla v. Federal Bureau of Investigation · No. 4:22-cv-02776
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a statute that permits certain civil-rights claims against state actors. The complaints were nearly identical. They named dozens of federal and state judges, various state courts, and federal officials as defendants, and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases. The opinion also notes that Bonilla had a pending federal petition challenging his detention, with appointed counsel.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without the fee only if the prisoner was under an imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other grounds cited by the court
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those grounds.
Ruling
The court dismissed the cases with prejudice. It also directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The court additionally stated that its impartiality could not reasonably be questioned because of the repetitive and frivolous nature of the filings. A footnote states that Bonilla named the judge as a defendant in one case, but the text provided does not complete the sentence describing that allegation.
Judge
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.