Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:24-cv-07841
- U.S. District Court · Northern District of California
- 2
Steven Bonilla v. San Francisco County Superior Court: Judge Hamilton dismissed the multiple cases with prejudice because he could not proceed without fees and the claims were barred.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice and closed. The order also terminated pending motions and directed the clerk to return future filings in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. San Francisco County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. He sued various federal and state judges and courts over his conviction and how other state and federal cases were handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The court found that his complaints did not show such a risk. It also said the lawsuits would be barred for other legal reasons even if he were allowed to proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further filings in the closed cases be returned without filing.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:24-cv-07841
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion says he is a condemned prisoner with a pending federal petition challenging his imprisonment in the same court, represented by appointed counsel, and that he is also represented by counsel in state-court proceedings. 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 and the handling of his other cases in state and federal court.
Proceeding Without Paying Filing Fees
The court addressed Bonilla’s requests, or possible requests, to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without paying those fees unless he was facing an immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger at the time of filing.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis explaining which rule applied to which complaint.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton dismissed the cases 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 submitted in the closed cases. The order states that Bonilla had an extensive history of filing similar frivolous cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.