Bonilla v. The Superior Court of Alameda County
- Phyllis Hamilton
- 4:20-cv-04306
- U.S. District Court · Northern District of California
- 2
In Bonilla v. The Superior Court of Alameda County, Judge Hamilton dismissed multiple cases with prejudice after denying fee-free status and finding legal barriers.
Steven Wayne Bonilla and his multiple civil-rights cases; the cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
What happened
In Bonilla v. The Superior Court of Alameda County, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights cases under a federal law that allows lawsuits against certain government actors. He named federal and state judges, municipalities, and other court officials.
Bonilla’s complaints raised similar issues about his conviction and how state and federal courts handled his other cases. The court found that his allegations did not show an immediate danger of serious physical injury, so he could not proceed without paying filing fees. The court also said that, even if he were allowed to proceed without those fees, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. The Superior Court of Alameda County · No. 4:20-cv-04306
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists these case numbers: 20-cv-04301-PJH, 20-cv-04303-PJH, 20-cv-04304-PJH, 20-cv-04305-PJH, 20-cv-04306-PJH, 20-cv-04307-PJH, 20-cv-04308-PJH, 20-cv-04309-PJH, 20-cv-04310-PJH, 20-cv-04311-PJH, 20-cv-04313-PJH, 20-cv-04315-PJH, 20-cv-04316-PJH, 20-cv-04317-PJH, and 20-cv-04318-PJH.
The complaints named various federal judges, state judges, municipalities, and other court officials. The court said the complaints presented very similar claims and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal court cases. The opinion also noted that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Reasoning
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That rule permits a disqualified prisoner to proceed without paying fees only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed.
The court found that Bonilla’s allegations did not show that he was in such danger at the time of filing. It therefore concluded that he could not proceed without paying filing fees. The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and lawsuits against federal courts or judges.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned. It cited the principle that, absent legitimate grounds for disqualification, 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. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The opinion does not separately describe the disposition of particular claims within the complaints; it states that the cases were dismissed with prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.