Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:24-cv-07265
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice after finding no imminent danger and several legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions in those cases without filing them.
What happened
In Bonilla v. Alameda County District Attorney’s Office, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, 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 was barred from proceeding without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found no such danger. It also stated that, even if he could proceed without paying the fee, the lawsuits would be barred by several legal doctrines and statutes, including rules concerning challenges to criminal convictions, ongoing state proceedings, and interference with other courts.
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 submits in those closed cases be returned without filing. The court also declined to recuse itself.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:24-cv-07265
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The opinion addresses numerous cases, including Case Nos. 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. Bonilla named various federal and state judges and state courts as defendants and sought relief concerning his underlying conviction or the way his other cases were handled. The opinion also notes that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Reason for dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was under imminent danger of serious physical injury at the time he filed a complaint. The court found that the allegations did not show imminent danger.
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several authorities. Those included Heck v. Humphrey, concerning civil-rights claims that would improperly challenge a criminal conviction; Younger v. Harris, concerning interference with ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
Recusal issue
Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her. The court concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the judge’s impartiality. It therefore did not recuse itself.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submits in those closed cases. The opinion states that the court had issued numerous prior orders concerning Bonilla’s cases and that he had filed many other similar cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.