In re Steven Wayne Bonilla
- Phyllis Hamilton
- 4:22-cv-05819
- U.S. District Court · Northern District of California
- 3
In In re Steven Wayne Bonilla, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the clerk was directed to close them and return later submissions without filing them.
What happened
In In re Steven Wayne Bonilla, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against county clerks and federal judges. He challenged his conviction and the handling of other court cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from that status and had not shown an imminent danger of serious physical injury. The court also said the lawsuits were barred by several legal doctrines and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- In re Steven Wayne Bonilla · No. 4:22-cv-05819
- Phyllis Hamilton
- Oct. 18, 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 named numerous county clerks and federal judges as defendants. The opinion states that the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other state and federal court cases.
The opinion also notes that Bonilla had a pending federal petition challenging his state-court custody, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status
Bonilla sought, or appeared to seek, permission to proceed without paying the filing fees. The court stated that he had already been disqualified from that status under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. It therefore ruled that Bonilla could not proceed without paying the filing fees.
Ruling
The court further stated that, even if Bonilla had been granted permission to proceed without paying fees, 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 court dismissed the cases with prejudice.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. 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.