Bonilla v. Mayfield
- Phyllis Hamilton
- 4:22-cv-03447
- 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 because Bonilla could not proceed without paying and the claims faced legal bars.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice. The named defendants included Marin County Superior Court, other state courts, federal officials, and dozens of federal and state judges. The clerk was directed to close the cases and return later documents without filing them.
What happened
Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against judges, courts, and government officials, challenging his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from that fee-waiver process and had not shown an immediate danger of serious physical injury. The court also said the lawsuits would be barred for other legal reasons even if he could proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return later filings without filing them.
The detailed version
- Bonilla v. Mayfield · No. 4:22-cv-03447
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against government actors. The complaints named dozens of federal and state judges, state courts, and federal officials. They raised nearly identical claims concerning Bonilla’s underlying conviction and the way state and federal courts handled his other cases.
The order covers multiple related cases, including Case Nos. 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.
Reasons for dismissal
The court stated that Bonilla had already been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate 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 allowed to proceed without paying the filing fee, the lawsuits would be barred under several legal doctrines and precedents, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, claims against federal courts, and judicial immunity. The order did not provide a separate merits decision on the underlying conviction or on the handling of Bonilla’s other cases.
The court also addressed impartiality. Although Bonilla named Judge Hamilton as a defendant in one case, the court concluded that the repetitive and frivolous nature of the filings did not itself provide a reason to question her impartiality.
Disposition
Judge Phyllis J. 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.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and other threshold legal bars 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.