Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:24-cv-07322
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without fees and his lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The clerk was directed to terminate pending motions and return future documents submitted in those closed cases without filing them.
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 other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not make that showing. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal doctrines concerning challenges to convictions, ongoing proceedings, and court actions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that future documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:24-cv-07322
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion lists these case numbers: 24-cv-6883-PJH, 24-cv-6885-PJH, 24-cv-6924-PJH, 24-cv-6925-PJH, 24-cv-7260-PJH, 24-cv-7261-PJH, 24-cv-7263-PJH, 24-cv-7264-PJH, 24-cv-7265-PJH, 24-cv-7311-PJH, 24-cv-7312-PJH, 24-cv-7313-PJH, 24-cv-7315-PJH, 24-cv-7316-PJH, 24-cv-7319-PJH, 24-cv-7320-PJH, 24-cv-7321-PJH, 24-cv-7322-PJH, 24-cv-7323-PJH, 24-cv-7378-PJH, 24-cv-7380-PJH, 24-cv-7381-PJH, and 24-cv-7382-PJH.
The complaints presented nearly identical claims against various federal and state judges and state courts. Bonilla sought relief related to his underlying conviction or the handling of his other cases by state and federal courts. The opinion also states that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court concluded that the allegations did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying the filing fee 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 opinion does not separately analyze each doctrine’s application to each case.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion notes that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her in those cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The opinion notes that the judge was the fourth judge assigned to Bonilla’s cases and describes an extensive history of similar filings. Those observations supported the court’s discussion of the repetitive nature of the filings but were not stated as a separate ruling.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.