Bonilla v. Casse
- Phyllis Hamilton
- 4:22-cv-03450
- 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 after finding Bonilla could not proceed IFP and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights lawsuits were dismissed with prejudice, and the cases were closed; the order also directed the clerk to return future submissions in those cases 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 federal officials. He sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla was barred from proceeding without paying the filing fee unless he showed an immediate serious physical danger, which his complaints did not show. The court also stated that the lawsuits would be barred by several legal rules even if his fee-waiver applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Casse · No. 4:22-cv-03450
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The order lists multiple related case numbers, including 22-cv-1900-PJH, 22-cv-2674-PJH, and others. The complaints presented nearly identical claims against dozens of federal and state judges, state courts, and federal officials. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court.
The order also notes that Bonilla had a pending federal petition concerning his custody in the same court, with appointed counsel.
Court’s reasoning
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner with qualifying prior dismissals from proceeding without paying the fee unless the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fee.
The court further stated that, even if a fee-waiver application 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, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those rules.
The court also addressed Bonilla’s naming of the judge as a defendant in one of the cases. It concluded that the repetitive and frivolous nature of the filings did not provide a reason to question the judge’s impartiality or require recusal.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.