Bonilla v. Del Norte County
- Phyllis Hamilton
- 4:20-cv-04310
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Del Norte County, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his suits faced legal bars.
Steven Wayne Bonilla and the defendants in the multiple related civil-rights cases, including federal judges, state judges, municipalities, and other court officials identified generally in the opinion.
What happened
In Bonilla v. Del Norte County, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights cases without a lawyer against federal judges, state judges, municipalities, and other court officials. He challenged his conviction and the handling of his petitions and other cases by state and federal courts.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not make that showing. It also said that, even if he could proceed without paying fees, the lawsuits would be barred under several legal rules and earlier decisions cited by the court.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Del Norte County · No. 4:20-cv-04310
- Phyllis Hamilton
- July 6, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against government officials. The opinion describes Bonilla as proceeding without a lawyer. The defendants included various federal judges, state judges, municipalities, and other court officials. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his petitions and other cases in state and federal court.
The opinion also states that Bonilla had a pending federal petition challenging his conviction or detention in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status
The court stated that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate 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 concluded that Bonilla could not proceed without paying the fees.
Additional grounds cited by the court
The court further stated that, even if Bonilla’s applications to proceed without paying fees were granted, the lawsuits would be barred under principles or authorities cited as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain the application of each cited authority to each case.
The court also rejected the suggestion that its impartiality could reasonably be questioned, stating that there were no legitimate reasons for the undersigned judge to recuse herself.
Ruling and 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.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton on July 6, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.