Bonilla v. Illman
- Phyllis Hamilton
- 4:24-cv-07379
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Francisco County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and the suits were barred.
Steven Wayne Bonilla and the multiple related civil-rights cases he filed; the listed defendants were federal and state judges and state courts.
What happened
In Bonilla v. San Francisco County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits. He named federal and state judges and state courts as defendants and sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not waive the filing fees because his allegations did not show that he faced an immediate serious physical danger when he filed the lawsuits. The court also said that, even if he could waive the fees, the lawsuits were barred by rules governing challenges to criminal convictions, ongoing state proceedings, and lawsuits against courts and judges. The cases were dismissed with prejudice.
Judge Hamilton also rejected the suggestion that the repetitive filings required her to step aside. She directed the clerk to end all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Illman · No. 4:24-cv-07379
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion lists these case numbers: 24-cv-7317-PJH, 24-cv-7377-PJH, 24-cv-7379-PJH, 24-cv-7526-PJH, 24-cv-7527-PJH, 24-cv-7840-PJH, 24-cv-7841-PJH, 24-cv-7842-PJH, 24-cv-7880-PJH, 24-cv-8010-PJH, 24-cv-8261-PJH, 24-cv-8263-PJH, 24-cv-8264-PJH, 24-cv-8265-PJH, and 24-cv-8266-PJH.
The complaints presented nearly identical claims against various federal and state judges and state courts. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. 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.
Filing-fee status and barriers to the lawsuits
To the extent Bonilla sought permission to proceed without paying filing fees, the court ruled that 28 U.S.C. § 1915(g) disqualified him from that status unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further ruled that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not resolve the underlying challenges to Bonilla’s conviction or the handling of his other cases.
Ruling
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the undersigned judge’s impartiality. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Judge Hamilton signed the order on November 25, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.