Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:24-cv-07316
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple federal civil-rights cases with prejudice after denying eligibility to proceed without paying fees.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice. He could not proceed without paying filing fees, all pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical federal civil-rights lawsuits against various federal and state judges and state courts. He sought relief concerning his conviction and the handling of his other cases. The opinion’s caption identifies the main defendant as the Alameda County District Attorney’s Office.
The court held that Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status and his complaints did not show an immediate danger of serious physical injury when filed. The court also said that, even if he could proceed without paying fees, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing proceedings, and interference with other courts.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents submitted in them without filing them. Judge Phyllis J. Hamilton also rejected any concern that her impartiality could reasonably be questioned based on the repetitive filings, although Bonilla named her as a defendant in three cases without making specific allegations.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:24-cv-07316
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints asserted 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.
The court noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody. The opinion also noted Bonilla’s extensive history of filing similar cases.
Filing-fee status
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. It therefore held that Bonilla could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of which cited rule applied to which case.
Ruling
The court dismissed the cases with prejudice. 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.
The court additionally addressed judicial impartiality. It concluded that these were not cases in which the undersigned judge’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 cases but made no specific allegations against her.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.