Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:24-cv-06924
- 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 after finding Bonilla could not proceed without prepaying filing fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and he may not proceed in them without prepaying filing fees. The named federal and state judges and courts were not required to litigate the claims in these cases.
What happened
In Steven Wayne 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 prepaying filing fees unless he showed that he faced an immediate danger of serious physical injury. The court said his complaints did not show that danger. It also said that, even if he were allowed to proceed without prepaying fees, the lawsuits would be barred under several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:24-cv-06924
- Phyllis Hamilton
- Oct. 24, 2024
Background
Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented 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 opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court, where he had appointed counsel, and that he was also represented by counsel in state-court proceedings concerning that petition. The opinion lists multiple related case numbers, including 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.
Court’s reasoning
The court addressed Bonilla’s ability to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without prepaying fees unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion also noted Bonilla’s extensive history of filing similar cases.
The court rejected any argument that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion noted that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against the judge 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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.