Bonilla v. Superior Court of Napa County, The
- Phyllis Hamilton
- 4:20-cv-06367
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court of Napa County, The, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and he could not proceed without paying filing fees because the court found no immediate danger of serious physical injury. The clerk was directed to close the cases and return further submissions without filing them.
What happened
In Bonilla v. Superior Court of Napa County, The, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against various state courts. He challenged his conviction and the handling of his other cases and petitions.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and statutes. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also rejected the suggestion that she should step aside because of Bonilla’s repeated filings. The clerk was directed to return any further documents Bonilla submitted in these closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of Napa County, The · No. 4:20-cv-06367
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. He represented himself in these cases. The complaints named various state courts as defendants and sought relief concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court. The opinion also notes that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status and dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), 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. Bonilla therefore could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying the filing 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, or Mullis v. U.S. Bankruptcy Court. The court dismissed the cases with prejudice. The opinion does not separately explain which specific bar applied to which complaint.
Recusal and case closure
The court also ruled that these cases did not provide a basis to question Judge Phyllis J. Hamilton’s impartiality because of the repetitive and allegedly frivolous nature of the filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Disposition
The multiple cases were dismissed with prejudice. The order did not grant permission to refile these cases. The clerk was also directed to close the cases and return later submissions without filing them.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.