Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:24-cv-07380
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits were barred.
The order affected Steven Wayne Bonilla’s multiple related civil-rights cases, which were dismissed with prejudice, and the defendants named in those cases. It also directed the clerk’s handling of later submissions in the closed cases.
What happened
Steven Wayne Bonilla v. Alameda County District Attorney’s Office and related cases involved multiple nearly identical complaints filed without a lawyer by a state prisoner under a federal civil-rights law. He named various federal and state judges and state courts and sought relief concerning his conviction or how other cases were handled.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying fees, the lawsuits were barred by legal rules identified in the order.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in the closed cases. The court also concluded that its judge’s impartiality could not reasonably be questioned based on the filings.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:24-cv-07380
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. He named various federal and state judges and state courts as defendants. The complaints sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody, in which he has appointed counsel. It also states that he is represented by counsel in state-court proceedings involving his custody.
Court’s reasons
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has previously filed qualifying cases generally may not proceed without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified from proceeding without paying fees and found that these complaints did not show imminent danger at the time of filing.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under legal rules identified in the order, including rules concerning challenges to criminal judgments, ongoing state proceedings, and certain challenges to court actions.
The court also rejected the suggestion that the assigned judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. A footnote states that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against the judge.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.