Bonilla v. Del Norte County Superior Court Clerks Office
- Phyllis Hamilton
- 4:25-cv-00351
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also affected the pending motions and future filings in those closed cases.
What happened
In Bonilla v. Averill et al., Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights cases against various federal and state judges and other officials. He challenged his conviction and how other cases had been handled.
The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without fees, several legal barriers would prevent the lawsuits from going forward.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all 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. Del Norte County Superior Court Clerks Office · No. 4:25-cv-00351
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple complaints under 42 U.S.C. § 1983, the federal law that allows civil-rights claims against certain government actors. He represented himself in these cases. The complaints presented nearly identical claims against various federal and state judges and other officials and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same district, with appointed counsel, and was represented by counsel in state-court proceedings.
Court’s analysis
Bonilla sought, or might have sought, permission to proceed without paying the filing fee. The court held that 28 U.S.C. § 1915(g) barred him from proceeding this way because he had previously been disqualified from that status and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them.
The court further held that, even if permission to proceed without paying the filing fee had been granted, the lawsuits would be barred by legal doctrines and rules identified in the opinion, including the rule concerning civil-rights claims that would undermine an existing criminal conviction, the rule limiting federal interference with certain ongoing state proceedings, a rule concerning repetitive or improper federal filings, and a rule concerning claims against federal judges or courts.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned merely because Bonilla repeatedly filed frivolous cases, including four cases naming her as a defendant without specific allegations against her. The opinion states that, absent legitimate grounds for recusal, a judge has a duty to decide assigned 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 opinion states that the cases had been assigned to four judges and that Judge Hamilton had issued 72 orders concerning 1,048 different cases filed by Bonilla since April 30, 2020. It also states that Bonilla had filed 962 other cases with the other three judges since 2011.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.