Bonilla v. Lake County Superior Court Judges
- Phyllis Hamilton
- 4:24-cv-08411
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed multiple civil-rights cases with prejudice because they lacked imminent-danger allegations and were legally barred.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice, and the named federal and state judges and other officials faced no further proceedings in these cases. The clerk was ordered to close the cases and return future submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and other officials. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying the filing fees because he had been barred from proceeding without fees unless he showed that he faced imminent danger of serious physical injury. The complaints did not show such danger. The court also said the lawsuits would be barred even if his applications to proceed without fees were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future submissions without filing them.
The detailed version
- Bonilla v. Lake County Superior Court Judges · No. 4:24-cv-08411
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state actors. The complaints were nearly identical. They named various federal and state judges and other officials as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel and was represented by counsel in state-court proceedings. The court also noted his history of filing similar cases.
Filing-fee restriction
The court addressed Bonilla’s possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without the fee may do so only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court determined that these complaints did not show imminent danger. Bonilla therefore could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal doctrines and authorities identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each doctrine in detail.
Ruling
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The court rejected the suggestion that the assigned judge’s impartiality could reasonably be questioned merely because Bonilla had filed repetitive and frivolous cases, noting that a judge has a duty to sit absent legitimate grounds for recusal. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.