Bonilla v. Simmons
- Phyllis Hamilton
- 4:22-cv-03449
- 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 fees and the suits were legally barred.
Steven Wayne Bonilla and the defendants named in the listed cases, including federal and state judges, state courts, and federal officials.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against judges, courts, and government officials. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate serious physical danger, which his complaints did not show. The court also said the lawsuits were barred by several legal rules even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to end 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. Simmons · No. 4:22-cv-03449
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple complaints under 42 U.S.C. § 1983, a federal civil-rights statute. The order covers the case numbers listed in the caption, including 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 against dozens of federal and state judges, various state courts, and federal officials. Bonilla sought relief concerning his underlying conviction and the way state and federal courts handled his other cases. The order also states that he had a pending federal petition concerning his conviction in the same court, with appointed counsel.
Court’s Analysis
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without prepaying filing fees, under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without prepaying fees only if he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger at the time of filing.
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 identified in the order, including rules concerning challenges to convictions, interference with ongoing state proceedings, and lawsuits against federal courts or judges. The opinion did not decide the underlying validity of Bonilla’s conviction or the merits of the allegations against the defendants.
The order also addressed impartiality. It stated that the repetitive and allegedly frivolous filings did not create a reasonable basis to question the undersigned judge’s impartiality. A footnote noted that Bonilla named the judge as a defendant in one case but presented no legitimate basis for recusal.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.