Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:24-cv-07320
- U.S. District Court · Northern District of California
- 3
Bonilla v. Alameda County District Attorney’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, and the clerk was ordered to close them and return future submissions without filing them.
What happened
In Steven Wayne Bonilla v. Alameda County District Attorney’s Office et. al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against judges and state courts. He challenged his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show that he faced an immediate risk of serious physical injury. The court also said that, even if he could proceed without paying, several legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:24-cv-07320
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal and state judges and state courts as defendants and sought relief related to Bonilla’s underlying conviction and the way other cases had been handled by state and federal courts.
The court noted that Bonilla had a pending federal petition challenging his imprisonment in the same district with appointed counsel, and that he was also represented by counsel in state-court proceedings concerning his imprisonment.
Filing-fee restriction
Bonilla sought, or might seek, permission to proceed without paying the filing fee. The court held that he was barred from doing so under 28 U.S.C. § 1915(g), unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such a danger.
Other legal barriers
The court further held that, even if Bonilla had been allowed to proceed without paying the filing fee, the lawsuits would be barred under several legal rules identified in the order: Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, which limits federal-court interference with certain ongoing state proceedings; and two other cited decisions concerning limits on these types of lawsuits.
The order also stated that Bonilla had an extensive history of filing similar cases. It noted that the judge was the fourth judge assigned to Bonilla’s cases, that the judge had issued 68 orders concerning 922 different cases since April 30, 2020, and that Bonilla had filed 962 other cases with the three other judges since 2011.
Ruling
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
The court separately rejected the argument that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The order noted that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against the judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.