Bonilla v. Mendocino County Superior Court Judges
- Phyllis Hamilton
- 4:24-cv-08263
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. San Francisco County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying filing restrictions.
Steven Wayne Bonilla's multiple cases were dismissed with prejudice and closed. He cannot proceed without paying the filing fee in these cases based on the court's application of the prisoner-filing restriction, and further submissions in the closed cases will be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases 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 paying the filing fee because he had previously been barred from proceeding without fees unless he showed imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and judicial actions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any additional documents Bonilla submits in these closed cases.
The detailed version
- Bonilla v. Mendocino County Superior Court Judges · No. 4:24-cv-08263
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers the cases numbered 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 and named various federal and state judges and state courts as defendants.
The order says Bonilla sought relief concerning his underlying conviction or the handling of his other cases in state and federal courts. It also states that he had a pending federal petition challenging his custody in this court with appointed counsel and was represented by counsel in state-court proceedings challenging his custody.
Reasons for dismissal
The court addressed Bonilla's possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has had qualifying prior cases dismissed generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had been disqualified from proceeding without paying under that statute and found that his allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the 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 provide a separate claim-by-claim analysis of those barriers.
The court also addressed judicial impartiality. It stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge's impartiality. The order noted that Bonilla named the judge as a defendant in two of the cases.
Ruling and case status
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submits in those closed cases.
Classification
This is a procedural order. The court dismissed the cases based on the filing-fee restriction and other threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.