Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:24-cv-07263
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County District Attorney’s Office, Judge Hamilton dismissed multiple prisoner cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla and the defendants named in the multiple cases were affected. The cases were closed, pending motions were terminated, and future documents Bonilla submits in those closed cases are to be returned without filing.
What happened
In Bonilla v. Alameda County District Attorney’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits under a federal law known as Section 1983. He named various federal and state judges and courts as defendants and sought relief concerning his conviction and the handling of other cases.
The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines and prior decisions.
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 detailed version
- Bonilla v. Alameda County Superior Court · No. 4:24-cv-07263
- Phyllis Hamilton
- Oct. 24, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government actors. He is a condemned prisoner with a pending federal petition challenging his detention or conviction in the same court, where he has appointed counsel. The opinion also states that he is represented by counsel in state court habeas proceedings.
The complaints presented nearly identical claims. Bonilla named various federal and state judges and state courts as defendants. He sought relief related to his underlying conviction and the way state and federal courts handled his other cases.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law generally prevents a prisoner with a qualifying history of frivolous or dismissed cases from proceeding without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when it was filed.
The court found that Bonilla’s allegations did not show such imminent danger. The court therefore concluded that he could not proceed without paying the filing fee.
Other Grounds for Dismissal
The court added that, even if an application to proceed without paying the filing fee were granted, the lawsuits would still be barred under the legal doctrines and decisions identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those grounds.
The court also stated that its impartiality could not reasonably be questioned merely because the filings were repetitive and frivolous. The opinion notes that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her in those cases.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submits in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.