Bonilla v. Ortez
- Phyllis Hamilton
- 4:22-cv-03319
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants named in those cases were not required to litigate the underlying claims, and the cases were closed.
What happened
In Bonilla v. Marin County Superior Court, et al., Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer. He sued dozens of federal and state judges, courts, and officials, seeking relief related to his conviction and the handling of his other cases.
The court said Bonilla had already been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury. The allegations did not show that risk. The court also said that, even if he could proceed without paying fees, the lawsuits would be barred by other legal rules.
The court dismissed all of the cases with prejudice, ended all pending motions, and closed the cases. It also ordered the clerk to return future documents Bonilla submitted in those closed cases without filing them. Judge Phyllis J. Hamilton signed the order.
The detailed version
- Bonilla v. Ortez · No. 4:22-cv-03319
- 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 identifies him as a condemned prisoner who also had a pending federal petition challenging his detention or conviction, with appointed counsel.
The complaints were nearly identical. Bonilla named dozens of federal and state judges, state courts, and federal officials as defendants. He sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying fees only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules or doctrines 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 separately explain which listed barrier applied to which case or claim.
The order also addressed impartiality. Although Bonilla named Judge Hamilton as a defendant in one of the cases, the court concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. The order states that Bonilla presented no legitimate reason for recusal.
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 those closed cases.
Classification
This is a procedural order because the court resolved the cases through filing-fee eligibility and other threshold legal barriers rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.