Bonilla v. Blum
- Phyllis Hamilton
- 4:23-cv-01279
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The ruling also affected the named federal and state judges and court officials, and directed the clerk’s office to close the cases, terminate pending motions, and return later submissions without filing them.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer against various federal and state judges and court officials. He sought relief concerning courts and also had pending habeas proceedings with appointed counsel and state-court proceedings with counsel.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status and his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by other legal rules.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also declined to recuse herself, and directed the clerk to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Blum · No. 4:23-cv-01279
- Phyllis Hamilton
- Mar. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints named various federal and state judges and court officials as defendants and sought relief concerning courts. The order covers the cases listed under Case Nos. 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.
The order also notes that Bonilla had a pending federal petition concerning his conviction or detention, with appointed counsel, and was represented by counsel in state-court proceedings.
Reasons for dismissal
The court addressed Bonilla’s possible request to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying fees only if he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger at the relevant time.
The court further stated that, even if Bonilla’s request to proceed without paying fees were granted, 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 order did not provide a separate detailed analysis of how each cited rule applied to each complaint.
Other ruling and disposition
The court rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. The order notes that Bonilla named the judge as a defendant in one case but presented no legitimate reason for recusal.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.