Bonilla v. Maier
- Phyllis Hamilton
- 4:22-cv-05125
- U.S. District Court · Northern District of California
- 2
Bonilla v. Wilken: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying legal barriers to the claims.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected any future documents he might submit in those closed cases, which the clerk was directed to return without filing.
What happened
In Bonilla v. Wilken, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights cases against dozens of federal and state judges and various state courts. He sought relief concerning his conviction and how his other cases had been handled.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying fees, the cases would be barred by several legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed them.
Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. The clerk was ordered to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Maier · No. 4:22-cv-05125
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical. They named dozens of federal and state judges and various state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings challenging his custody.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner previously disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore held that he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without fees 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 opinion did not provide a separate claim-by-claim analysis of those legal rules.
The court also addressed judicial impartiality. It stated that the cases did not present circumstances in which the presiding judge’s impartiality could reasonably be questioned merely because the filings were repetitive and frivolous. The opinion notes that Bonilla named the presiding judge as a defendant in two of the cases but did not provide a legitimate reason for disqualification.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk 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 the filing-fee restriction and other threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.