Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:24-cv-07321
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and procedural barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. All pending motions were terminated, the cases were closed, and further documents he submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. Alameda County District Attorney’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various federal and state judges and state courts. He sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not waive the filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could waive the fees, the lawsuits would be barred by several legal rules and prior decisions because they challenged his conviction or court proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:24-cv-07321
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against certain government actors. He represented himself in these cases. The opinion states that he is a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and that he is also represented by counsel in state court proceedings.
The complaints presented nearly identical claims and named various federal and state judges and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.
Reasons for dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fees under 28 U.S.C. § 1915(g). That rule permits a prisoner with the relevant filing history to proceed without paying fees only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion also noted Bonilla’s extensive history of filing similar cases.
The court rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion noted that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court directed 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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.