Bonilla v. Alameda County District Attorney
- Phyllis Hamilton
- 4:23-cv-01728
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Ortez, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. He could not proceed without paying filing fees, the cases were closed, pending motions were terminated, and future documents submitted in those closed cases were ordered returned without filing.
What happened
In Steven Wayne Bonilla v. Judge Elia Ortez and others, Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights cases against judges and county officials. He challenged his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said the lawsuits would be barred even if he qualified to proceed without fees.
Judge Hamilton dismissed the cases with prejudice, directed the clerk to close them and terminate all pending motions, and ordered that future documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Alameda County District Attorney · No. 4:23-cv-01728
- Phyllis Hamilton
- Apr. 14, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists these case numbers: 23-cv-1282-PJH, 23-cv-1415-PJH, 23-cv-1416-PJH, 23-cv-1575-PJH, 23-cv-1576-PJH, 23-cv-1577-PJH, 23-cv-1579-PJH, 23-cv-1580-PJH, 23-cv-1581-PJH, 23-cv-1582-PJH, 23-cv-1625-PJH, 23-cv-1627-PJH, 23-cv-1667-PJH, 23-cv-1668-PJH, 23-cv-1669-PJH, 23-cv-1670-PJH, 23-cv-1671-PJH, 23-cv-1673-PJH, 23-cv-1728-PJH, 23-cv-1729-PJH, 23-cv-1730-PJH, 23-cv-1731-PJH, and 23-cv-1732-PJH.
The complaints presented nearly identical claims against various federal and state judges and county officials. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The opinion also notes that he had a pending federal petition challenging his custody in this court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding in civil cases without paying filing fees unless he showed that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that his allegations did not show such danger. Accordingly, Bonilla could not proceed without paying the filing fees.
Other barriers to the lawsuits
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, which can prevent civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine as to each case.
Disposition
The court dismissed the cases with prejudice. It also rejected any concern that Judge Hamilton's impartiality could reasonably be questioned because of Bonilla's repetitive and frivolous filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
The court entered the order on April 14, 2023, signed by Phyllis J. Hamilton, United States District Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.