Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:22-cv-05127
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Judge Wilken, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice and closed. The order also ended pending motions and instructed the clerk not to file further documents submitted in those closed cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under a federal law allowing claims against state officials. He sued dozens of federal and state judges and courts over his conviction and how his other cases were handled.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that status and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by other legal rules even if that status were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:22-cv-05127
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983. Those cases presented nearly identical claims and named dozens of federal and state judges and various state courts as defendants. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal court cases.
The order also stated that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status
Bonilla sought, or might have sought, permission to proceed without paying the filing fee at the outset. The court stated that he was disqualified from that status under 28 U.S.C. § 1915(g) unless he was facing imminent danger of serious physical injury when he filed. The court found that his allegations did not show such danger at the relevant time.
Other grounds identified by the court
The court further stated that, even if Bonilla’s request to proceed without paying the filing fee were granted, 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 claims; it dismissed the cases based on the filing-fee restriction and those additional legal bars.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
The court additionally stated that the repetitive and frivolous nature of the filings did not create a situation in which the assigned judge’s impartiality could reasonably be questioned. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.