Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:24-cv-07842
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Francisco County Superior Court, Judge Hamilton dismissed multiple prisoner lawsuits with prejudice under filing and claim-bar rules.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named federal and state judge and court defendants were affected by the closure of those cases, and the clerk was directed to terminate pending motions and return later submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against various federal and state judges and courts. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without prepaying filing fees because he did not show that he faced an imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred even if he could proceed without paying those fees, and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also rejected any claim that the repetitive filings required her to step aside. The clerk was ordered to terminate pending motions, close the cases, and return any further documents Bonilla submits in them without filing them.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:24-cv-07842
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, identified in the order as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal and state judges and state courts as defendants. The order says the complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases.
The order also notes that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings. Those proceedings are described in the order as separate from the cases dismissed here.
Filing-fee restriction
The court addressed Bonilla’s possible request to proceed without prepaying filing fees, commonly called proceeding in forma pauperis or proceeding without paying fees in advance. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from using that procedure unless he was in imminent danger of serious physical injury when he filed his complaints.
The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without prepaying the filing fees.
Other barriers to the lawsuits
The court further stated that, even if an application to proceed without prepaying 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, and Mullis v. U.S. Bankruptcy Court. The order did not separately analyze each case or claim under those authorities.
Ruling
The court dismissed the cases with prejudice. 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 rejected the suggestion that her impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The order states that a judge has a duty to sit in cases assigned to that judge absent legitimate grounds for recusal. A footnote states that Bonilla named Judge Hamilton as a defendant in two of the cases, but the supplied opinion text cuts off before completing that footnote.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.