Bonilla v. Mayfield
- Phyllis Hamilton
- 4:22-cv-05400
- U.S. District Court · Northern District of California
- 3
Judge Hamilton dismissed Bonilla v. Katz and related cases with prejudice, finding Bonilla could not proceed without fees and that his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named judges and county clerks were defendants, and the clerk was directed to close the cases and return future submissions without filing them.
What happened
In Bonilla v. Judge Steven M. Katz and related cases, Steven Wayne Bonilla filed several civil-rights lawsuits without a lawyer. He challenged his conviction and the handling of his other cases by state and federal courts, naming judges and county clerks as defendants.
Bonilla sought to proceed without paying filing fees. The court said he was barred from doing so unless he showed that he faced an immediate risk of serious physical injury when he filed, and that his complaints did not make that showing. The court also said the lawsuits would be barred even if fee-free status were allowed.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, ordered the clerk to end pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Mayfield · No. 4:22-cv-05400
- Phyllis Hamilton
- Sept. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a law that permits certain civil-rights claims against state officials. The complaints were nearly identical. They named numerous state and federal judges and county clerks and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same district court, with appointed counsel, and was represented by counsel in state court proceedings.
Fee-free filing status
Bonilla sought, or potentially sought, permission to proceed without paying filing fees. The court stated that he had previously been disqualified from that status under 28 U.S.C. § 1915(g), unless he was under an imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger at the relevant time. The opinion therefore stated that Bonilla could not proceed without paying the required fees.
Reasons for dismissal
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under one or more of the legal rules identified in the opinion: Heck v. Humphrey, which can restrict civil-rights claims that would undermine a conviction; Younger v. Harris, which concerns federal interference with certain ongoing state proceedings; and Ninth Circuit authorities concerning similar claims against courts or judges. The opinion did not separately identify which rule applied to which complaint.
The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality. It cited the principle that, absent legitimate grounds for disqualification, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.