Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:24-cv-09497
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without paying filing fees and his suits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named federal and state judges and other officials were defendants in those cases.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights complaints. He sued federal and state judges and other officials over his conviction and how other state and federal court cases were handled.
The court found that Bonilla could not proceed without paying the filing fees because he had been barred from proceeding without them unless he showed an immediate danger of serious physical injury. The complaints did not show that danger. The court also ruled that, even if he could proceed without paying fees, the lawsuits were barred by several legal doctrines, and it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton issued the order. She directed the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:24-cv-09497
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal and state judges and other officials and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The order addressed multiple cases, including case numbers 24-cv-8847-PJH, 24-cv-8857-PJH, 24-cv-9025-PJH, 24-cv-9026-PJH, 24-cv-9152-PJH, 24-cv-9153-PJH, 24-cv-9175-PJH, 24-cv-9256-PJH, 24-cv-9257-PJH, 24-cv-9258-PJH, 24-cv-9259-PJH, 24-cv-9260-PJH, 24-cv-9261-PJH, 24-cv-9262-PJH, 24-cv-9263-PJH, 24-cv-9264-PJH, 24-cv-9266-PJH, 24-cv-9267-PJH, 24-cv-9269-PJH, 24-cv-9270-PJH, 24-cv-9271-PJH, 24-cv-9272-PJH, 24-cv-9281-PJH, 24-cv-9282-PJH, 24-cv-9284-PJH, 24-cv-9458-PJH, 24-cv-9459-PJH, 24-cv-9460-PJH, 24-cv-9461-PJH, 24-cv-9491-PJH, 24-cv-9492-PJH, 24-cv-9495-PJH, 24-cv-9496-PJH, 24-cv-9497-PJH, 24-cv-9498-PJH.
Filing-fee ruling
Bonilla sought, or attempted to seek, permission to proceed without paying filing fees. The court stated that 28 U.S.C. § 1915(g) disqualified him from proceeding that way unless he was “under imminent danger of serious physical injury” when he filed the complaints. The court found that the allegations did not show such danger at the time of filing. It therefore ruled that Bonilla could not proceed without paying the filing fees.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying filing 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 order did not resolve the underlying conviction or the alleged mishandling of Bonilla’s other cases on their merits.
Disposition
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. Judge Phyllis J. Hamilton additionally rejected the suggestion that her impartiality could reasonably be questioned because of the repetitive and frivolous filings, noting that Bonilla named her as a defendant in two of the cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.