Bonilla v. U.S. District Court, San Jose
- Phyllis Hamilton
- 4:24-cv-07527
- 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 after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla’s multiple listed civil-rights cases were dismissed with prejudice, all pending motions were terminated, and the cases were closed. The order also directs the clerk not to file further documents submitted in those closed cases.
What happened
In Steven Wayne Bonilla v. San Francisco County Superior Court et al., Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against federal and state judges and state courts. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from that status and his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if he were allowed to proceed without paying the fee.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further submissions without filing them.
The detailed version
- Bonilla v. U.S. District Court, San Jose · No. 4:24-cv-07527
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a statute that allows certain claims against government officials for violating federal rights. The complaints were nearly identical. They named various federal and state judges and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same district, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning his custody.
Proceeding Without the Filing Fee
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other Legal Bars
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules and decisions cited in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not conduct a merits determination that Bonilla’s underlying claims were legally correct.
Ruling and Case Administration
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 assigned judge’s impartiality. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Judge Phyllis J. 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.