Bonilla v. Humboldt County Superior Court Judges
- Phyllis Hamilton
- 4:24-cv-08261
- U.S. District Court · Northern District of California
- 2
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 his lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the defendants named in those cases were not required to litigate the claims further in those actions.
What happened
In Steven Wayne Bonilla v. San Francisco County Superior Court et al., Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer. He named various federal and state judges and state courts and challenged his conviction or how other courts handled his cases.
The court said Bonilla could not proceed without paying filing fees because he had been barred from that status unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his allegations did not show such a danger. It also said that, even if he were allowed to proceed without paying, the lawsuits would be barred under several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Humboldt County Superior Court Judges · No. 4:24-cv-08261
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple similar complaints under 42 U.S.C. § 1983, the federal law that allows civil-rights claims against state actors. He represented himself in these cases. The complaints named various federal and state judges and state courts and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The order covered the following related 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.
Court’s analysis
The court addressed Bonilla’s possible request to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), the court said he had been disqualified from that status unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger.
The court further stated that, even if a request to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order also stated that Bonilla had an extensive history of filing similar frivolous cases.
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned merely because of the repetitive and frivolous filings. The order noted that Bonilla named the judge as a defendant in two of the cases.
Disposition
The cases were dismissed with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.