Bonilla v. Superior Court of California, County of San Francisco
- Phyllis Hamilton
- 4:22-cv-03425
- U.S. District Court · Northern District of California
- 3
In Steven Wayne 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 lawsuits were dismissed with prejudice, and the cases were closed; the named federal and state defendants were not required to litigate the claims further.
What happened
In Steven Wayne Bonilla v. Marin County Superior Court, Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer. He challenged his conviction and the handling of his other cases, naming many federal and state judges, courts, and officials.
The court found that Bonilla had previously been barred from proceeding without paying the filing fee unless he showed an immediate risk of serious physical injury. His complaints did not show that kind of danger. The court also said the lawsuits would be barred by several legal rules even if he had been allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, ended the pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of California, County of San Francisco · No. 4:22-cv-03425
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the related cases numbered 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, state courts, and federal officials. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled. The order also states that he was a condemned prisoner and had a pending federal petition concerning his detention in the same court, with appointed counsel.
Court’s analysis
Bonilla sought, or might have sought, permission to proceed without paying the filing fee. The court held that he had previously been disqualified from that status under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if Bonilla had been granted permission to proceed without paying the fee, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying validity of Bonilla’s conviction or the merits of each civil-rights claim.
The court also rejected any suggestion that Judge Phyllis J. Hamilton’s impartiality could 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 presented no legitimate basis for recusal.
Disposition
Judge Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.