Bonilla v. San Mateo County Superior Court Judges
- Phyllis Hamilton
- 4:24-cv-08265
- U.S. District Court · Northern District of California
- 2
In Steven Bonilla v. San Francisco County Superior Court, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. San Francisco County Superior Court et. al., the plaintiff, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against federal and state judges and courts. He challenged his conviction or how other courts handled his cases.
The court said Bonilla could not proceed without paying the filing fees because he had been disqualified from that status unless he showed an imminent danger of serious physical injury. The complaints did not show such danger. The court also said the cases would be barred by several legal rules even if his fee applications were granted.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, ended the pending motions, closed the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. San Mateo County Superior Court Judges · No. 4:24-cv-08265
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983, a federal statute that allows certain claims against state actors. 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 his other cases had been handled by state and federal courts.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings concerning that petition.
Court's Analysis
The court addressed Bonilla's ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that these allegations did not show such danger, so Bonilla could not proceed without paying the filing fees.
The court further ruled that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain which rule applied to which case or claim.
The court also addressed impartiality. It stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the undersigned judge's impartiality. The opinion notes that Bonilla named the judge as a defendant in two of the cases.
Disposition
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 submitted in those 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.