Bonilla v. Sonoma County
- Phyllis Hamilton
- 4:20-cv-05598
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sonoma County, Judge Hamilton dismissed the cases with prejudice after finding Bonilla could not proceed under a fee waiver and his lawsuits were barred.
Steven Wayne Bonilla's 15 related civil-rights cases were dismissed with prejudice and closed. The opinion does not identify the defendants individually in the caption, but says they included federal and state judges, municipalities, and other municipal and court officials.
What happened
In Bonilla v. Sonoma County, Steven Wayne Bonilla, a condemned state prisoner, filed multiple civil-rights lawsuits without a lawyer against federal and state judges, municipalities, and other officials. His complaints raised similar issues about his conviction and how courts handled his other cases.
The court found that Bonilla could not proceed without paying filing fees because he had been disqualified from that status and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal doctrines.
Judge Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return future submissions without filing them.
The detailed version
- Bonilla v. Sonoma County · No. 4:20-cv-05598
- 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 listed cases included 15 related case numbers. The complaints named various federal judges, state judges, municipalities, and other municipal and court officials as defendants.
The court said Bonilla's claims were very similar across the cases. They sought relief concerning his underlying conviction and the handling of his other petitions and lawsuits in state and federal court. The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Court's analysis
The court addressed Bonilla's ability to proceed in forma pauperis, meaning without prepaying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has had three or more qualifying cases dismissed generally cannot use that status unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified under this rule and that his allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not analyze each doctrine separately or decide the underlying validity of Bonilla's conviction and other court-related claims.
The court also stated that the circumstances did not provide a basis for reasonably questioning the undersigned judge's impartiality. It cited the general principle that, absent legitimate grounds for recusal, an assigned judge has a duty to decide the cases.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification basis
This is a procedural order. The court disposed of the cases based on Bonilla's inability to proceed without prepaying fees and stated procedural or claim-bar grounds, rather than deciding the underlying merits of his civil-rights allegations.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.