Bonilla v. Jackson
- Phyllis Hamilton
- 4:22-cv-03446
- U.S. District Court · Northern District of California
- 3
Bonilla v. Marin County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after Bonilla could not proceed without paying fees and the claims faced legal bars.
Steven Wayne Bonilla's multiple § 1983 cases were dismissed with prejudice, preventing those cases from continuing. The order also terminated pending motions and directed the clerk to return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Marin County Superior Court, et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases. He challenged his conviction and the handling of his other cases, naming many judges, courts, and government officials.
Bonilla could not proceed without paying filing fees unless his complaints showed that he faced an immediate risk of serious physical injury. The court found that they did not. The court also said that, even if he could proceed without paying fees, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return without filing any additional documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Jackson · No. 4:22-cv-03446
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order lists these case numbers: 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 court said the complaints presented nearly identical claims. Bonilla named dozens of federal and state judges, various state courts, and federal officials. The complaints sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. The order also stated that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel.
Filing-fee eligibility
The court addressed Bonilla's ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying fees may do so only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The order stated that Bonilla had previously been disqualified under that provision.
The court found that the allegations in these complaints did not show immediate danger of serious physical injury at the time of filing. Therefore, Bonilla could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim explanation of which authority applied to which complaint.
Ruling and disposition
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. A footnote stated that Bonilla named Judge Hamilton as a defendant in one case but did not present a legitimate basis for disqualification.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further 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.