Bonilla v. Contra Costa County Superior Court Judges
- Phyllis Hamilton
- 4:24-cv-08412
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice because Bonilla could not proceed without fees and the suits were barred.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice; pending motions were terminated and the cases were closed.
What happened
In Steven Wayne Bonilla v. U.S. District Court San Francisco et al., Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer under a federal law allowing claims against state officials. He named federal and state judges and other officials and challenged his conviction or the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from that status and his allegations did not show immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal doctrines and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return any further submissions without filing them. The court also rejected the argument that the judge’s impartiality could reasonably be questioned because of the repetitive filings.
The detailed version
- Bonilla v. Contra Costa County Superior Court Judges · No. 4:24-cv-08412
- Phyllis Hamilton
- Dec. 16, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the cases listed under these case numbers: 24-cv-7972-PJH, 24-cv-8268-PJH, 24-cv-8410-PJH, 24-cv-8411-PJH, 24-cv-8412-PJH, 24-cv-8413-PJH, 24-cv-8414-PJH, 24-cv-8472-PJH, 24-cv-8473-PJH, 24-cv-8501-PJH, 24-cv-8553-PJH, 24-cv-8554-PJH, 24-cv-8555-PJH, 24-cv-8632-PJH, 24-cv-8842-PJH, 24-cv-8843-PJH, 24-cv-8844-PJH, 24-cv-8845-PJH, 24-cv-8846-PJH, 24-cv-8848-PJH, 24-cv-8849-PJH, 24-cv-8850-PJH, 24-cv-8851-PJH, 24-cv-8852-PJH, 24-cv-8854-PJH, 24-cv-8855-PJH, 24-cv-8856-PJH, 24-cv-8858-PJH, 24-cv-9022-PJH, and 24-cv-9024-PJH.
The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. The order also states that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status
The court explained that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other bars to the lawsuits
The court further stated that, even if an application 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 opinion did not separately analyze each case or claim under those authorities before announcing its disposition.
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 the closed cases.
The court also addressed judicial impartiality. It concluded that the repetitive and allegedly frivolous nature of the filings did not provide a reason to question the undersigned judge’s impartiality. Judge Phyllis J. Hamilton signed the order on December 16, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.