Bonilla v. Sonoma County Superior Court Judges
- Phyllis Hamilton
- 4:24-cv-08266
- 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 because Bonilla could not proceed without fees and the claims were legally barred.
Steven Wayne Bonilla's multiple lawsuits, the named federal and state judges and state courts, and the pending motions and filings in those cases.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits without a lawyer against various federal and state judges and state courts. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla could not proceed without prepaying filing fees because he had previously been disqualified from that status and his complaints did not show imminent danger of serious physical injury. The court also said the lawsuits would be barred under several legal doctrines even if he were allowed to proceed without prepaying fees.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also rejected the suggestion that the repetitive filings required her to step aside.
The detailed version
- Bonilla v. Sonoma County Superior Court Judges · No. 4:24-cv-08266
- Phyllis Hamilton
- Nov. 25, 2024
Background
Steven Wayne Bonilla filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights law. The opinion identifies Bonilla as a state prisoner and a condemned prisoner. He named various federal and state judges and state courts as defendants. The complaints presented nearly identical claims and sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.
The opinion also notes that Bonilla had a pending federal habeas petition in the district court with appointed counsel and was represented by counsel in state habeas proceedings.
Filing-fee status
The court explained that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying filing fees, under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed in forma pauperis in these cases.
Other grounds identified by the court
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine in detail before entering its disposition.
Recusal issue
The court also addressed the fact that Bonilla named the undersigned judge as a defendant in two of the cases. It concluded that these were not cases in which the judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The court cited the rule that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases 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. Judge Phyllis J. Hamilton signed the order on November 25, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.