Bonilla v. Judge Clay
- Phyllis Hamilton
- 4:23-cv-01275
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named federal and state judges and court officials were defendants in those cases.
What happened
In Bonilla v. Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer against federal and state judges and court officials. He sought relief concerning courts.
The court said Bonilla could not proceed without paying filing fees because he had been disqualified under federal law and had not shown that he faced imminent danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred under several other legal rules, even if permission to proceed without paying fees were granted.
The court dismissed all the cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases and return future documents without filing them. Judge Phyllis J. Hamilton also rejected the suggestion that her impartiality could reasonably be questioned based on the filings.
The detailed version
- Bonilla v. Judge Clay · No. 4:23-cv-01275
- Phyllis Hamilton
- Mar. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state judges and court officials as defendants and sought relief concerning courts. The order covered the related cases numbered 23-cv-0851-PJH, 23-cv-1071-PJH, 23-cv-1236-PJH, 23-cv-1275-PJH, 23-cv-1276-PJH, 23-cv-1278-PJH, 23-cv-1279-PJH, 23-cv-1280-PJH, 23-cv-1283-PJH, 23-cv-1284-PJH, 23-cv-1285-PJH, 23-cv-1286-PJH, 23-cv-1287-PJH, 23-cv-1331-PJH, 23-cv-1333-PJH, 23-cv-1355-PJH, and 23-cv-1356-PJH.
Court’s reasoning
The court stated that, to the extent Bonilla sought permission to proceed without paying filing fees, federal law disqualified him from doing so unless he was facing imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.
The court further stated that, even if permission to proceed without paying fees were granted, the lawsuits would be barred under several legal rules and decisions, including rules concerning challenges to criminal convictions, ongoing state proceedings, claims against federal courts, and claims involving judicial immunity. The order did not separately analyze the merits of the underlying allegations.
The court also addressed impartiality. It said the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. A footnote states that Bonilla named the judge as a defendant in one case but presented no legitimate reason for recusal.
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. The order was signed by Judge Phyllis J. Hamilton on March 27, 2023.
This is classified as a procedural order because the court disposed of the cases based on filing-fee eligibility and other threshold or legal-bar grounds rather than deciding the underlying civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.