Bonilla v. Superior Court of Sonoma County
- Phyllis Hamilton
- 4:20-cv-05776
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court of Sonoma County, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without paying fees and that other legal rules barred them.
Steven Wayne Bonilla’s multiple self-represented civil-rights lawsuits were dismissed with prejudice. The order also affected the defendants named in those cases and barred further filings in the closed cases from being filed.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights lawsuits under a federal law that allows claims against government officials. He sued federal and state judges, municipalities, and other government and court officials, challenging his conviction and how courts handled his filings.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from proceeding without fees and his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if he could proceed without paying, the lawsuits would be barred by other legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also ruled that there was no stated basis to question her impartiality. She directed the clerk to return future filings in the closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of Sonoma County · No. 4:20-cv-05776
- Phyllis Hamilton
- Aug. 20, 2020
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 named various federal judges, state judges, municipalities, and other municipal and court officials. The court said the cases presented very similar claims concerning Bonilla’s underlying conviction and the handling of his self-represented habeas petitions and other court cases.
The opinion also noted that Bonilla had a pending federal habeas petition in the same district with appointed counsel and was represented by counsel in state habeas proceedings.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he showed that he was in imminent danger of serious physical injury when he filed his complaint. The court found that the allegations in these cases did not show such imminent danger. It therefore ruled that Bonilla could not proceed without paying the filing fees.
Additional Grounds for Dismissal
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those grounds.
Ruling and Disposition
The court dismissed the cases with prejudice. It also ruled that the circumstances did not provide a basis to reasonably question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.