Bonilla v. Superior Court of Mendocino County
- Phyllis Hamilton
- 4:20-cv-05652
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying several legal bars.
Steven Wayne Bonilla and the defendants in his multiple civil-rights cases; the cases were closed, pending motions were terminated, and later filings were to be returned without filing.
What happened
In Bonilla v. Superior Court of Mendocino County, the court dismissed multiple civil-rights cases filed by Steven Wayne Bonilla, a state prisoner who was representing himself.
Bonilla sought relief related to his conviction and to how state and federal courts handled his other cases. The court found that his complaints did not show he faced an immediate risk of serious physical harm when he filed them, so he could not proceed without paying the filing fees. The court also stated that the lawsuits were barred by several legal rules and prior decisions.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return later filings. Judge Phyllis J. Hamilton also stated that her impartiality could not reasonably be questioned.
The detailed version
- Bonilla v. Superior Court of Mendocino County · No. 4:20-cv-05652
- Phyllis Hamilton
- Aug. 20, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases named various federal judges, state judges, municipalities, and other municipal and court officials as defendants. The complaints presented similar claims seeking relief related to Bonilla’s underlying conviction and to the handling of his other petitions and cases in state and federal court.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment, with appointed counsel, and was also represented by counsel in state proceedings concerning that petition.
Filing-fee status
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) barred him from doing so unless he showed that 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.
Other legal barriers
The court further stated that, even if permission to proceed without paying the filing fee had been granted, the lawsuits would be barred under several legal authorities: 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 which authority applied to which claim or case.
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 additional documents Bonilla submitted in the closed cases.
The court also addressed whether the judge’s impartiality might reasonably be questioned and concluded that these were not cases requiring the judge’s recusal. Judge Phyllis J. Hamilton signed the order on August 20, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.