Bonilla v. The Superior Court of Humboldt County
- Phyllis Hamilton
- 4:20-cv-06002
- U.S. District Court · Northern District of California
- 2
In Bonilla v. The Superior Court of Humboldt County, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla's multiple self-represented civil-rights cases were dismissed with prejudice. The court also terminated the pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights lawsuits against state courts and others. His complaints concerned his conviction and the handling of his habeas petitions and other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been disqualified from proceeding without fees and had not shown imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines. It dismissed the cases with prejudice, terminated the pending motions, and closed the cases.
Judge Phyllis J. Hamilton also declined to recuse herself, explaining that the repetitive and frivolous nature of the filings did not reasonably call her impartiality into question. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. The Superior Court of Humboldt County · No. 4:20-cv-06002
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion identifies him as a condemned prisoner who had a pending federal petition challenging his custody, with appointed counsel, and state-court proceedings in which he was represented by counsel. In the civil-rights cases, he named various state courts as defendants and sought relief concerning his underlying conviction and the handling of his self-represented habeas petitions and other cases.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger. It therefore ruled that he could not proceed without paying the filing fee.
Other Grounds for Dismissal
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the doctrines 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 separately explain how each doctrine applied to each 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 further documents Bonilla submitted in those closed cases.
Recusal
The court also addressed whether the judge's impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. Judge Phyllis J. Hamilton concluded that these were not cases requiring recusal and cited the principle that, absent legitimate reasons, a judge has a duty to decide cases assigned to that judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.