Bonilla v. Superior Court, County of Del Norte
- Phyllis Hamilton
- 4:21-cv-01224
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Judge Beth L. Freeman, Judge Hamilton dismissed multiple cases with prejudice after finding Bonilla could not file without fees and his claims were barred.
Steven Wayne Bonilla, who represented himself in the lawsuits, and the federal judges, state judges, court staff, and state and federal agencies he named as defendants. The order closed all of the listed cases.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights lawsuits against federal and state judges, court staff, and state and federal agencies. He challenged his conviction and how courts handled his cases and habeas petitions.
The court found that Bonilla was barred from filing without paying fees unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said the lawsuits were barred by several legal rules, even if his fee applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of Del Norte · No. 4:21-cv-01224
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, a state prisoner under a death sentence, filed multiple lawsuits representing himself under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against people acting under state law. The defendants included federal judges, state judges, court staff, and state and federal agencies. The complaints raised similar issues involving Bonilla’s underlying conviction and the handling of his self-filed habeas petitions and other cases in state and federal court.
The order covered these case numbers: 21-cv-01090-PJH, 21-cv-01163-PJH, 21-cv-01188-PJH, 21-cv-01189-PJH, 21-cv-01190-PJH, 21-cv-01223-PJH, 21-cv-01224-PJH, 21-cv-01225-PJH, 21-cv-01242-PJH, 21-cv-01243-PJH, 21-cv-01244-PJH, 21-cv-01245-PJH, 21-cv-01246-PJH, 21-cv-01247-PJH, 21-cv-01248-PJH, 21-cv-01249-PJH, and 21-cv-01250-PJH.
The court noted that Bonilla had a pending federal habeas petition in the district, with appointed counsel, and was represented by counsel in state habeas proceedings. The order also noted that Bonilla named Judge Hamilton as a defendant in one of the cases, but that complaint made no specific allegations against her.
Court’s analysis
The court held that Bonilla could not proceed without paying the filing fees under 28 U.S.C. § 1915(g). That statute generally disqualifies a prisoner from proceeding without fees after qualifying prior cases, unless the prisoner shows that he faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without fees were granted, the lawsuits would be barred under the rules 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 provide a separate claim-by-claim analysis explaining which bar applied to which complaint.
Ruling and effect
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 these closed cases. The court additionally concluded that the repetitive and allegedly frivolous filings did not provide a basis to question Judge Hamilton’s impartiality or require her recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.