Bonilla v. Clay
- Phyllis Hamilton
- 4:22-cv-05360
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Clay, Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and identifying several legal bars.
Steven Wayne Bonilla's multiple § 1983 cases were dismissed with prejudice. The state courts and judges he named as defendants were not required to litigate the claims, and the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Bonilla v. Clay, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state courts and judges. He challenged his conviction and the way other cases had been handled.
The court said Bonilla could not proceed without paying filing fees because he had previously been barred from that status and had not shown that he faced an immediate danger of serious physical injury when he filed. 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 the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future documents without filing them.
The detailed version
- Bonilla v. Clay · No. 4:22-cv-05360
- Phyllis Hamilton
- Sept. 26, 2022
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. He also had a pending federal petition challenging his detention and was represented by counsel in state-court proceedings concerning that petition.
The complaints presented nearly identical claims and named numerous state courts and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
Court’s analysis
The court addressed Bonilla’s requests to proceed in forma pauperis, meaning without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner previously disqualified from that status may proceed without paying only if he shows that he was in imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if an application to proceed without paying the filing fee 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 therefore disposed of the cases on filing-status and other legal-bar grounds rather than deciding the underlying claims.
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 the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.