Bonilla v. Superior Court, County of Mendocino
- Phyllis Hamilton
- 4:21-cv-01243
- U.S. District Court · Northern District of California
- 3
Bonilla v. Freeman: Judge Hamilton dismissed Steven Wayne Bonilla’s multiple civil-rights cases with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Steven Wayne Bonilla’s multiple cases against judges, court staff, and government agencies, he challenged his conviction and how courts handled his other cases. He filed the complaints without a lawyer under a federal civil-rights law.
The court found that Bonilla could not file without paying the required fees because he had previously been barred from doing so unless he faced imminent danger of serious physical injury. His complaints did not show that danger. The court also said the lawsuits would be barred for other legal reasons, even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
The detailed version
- Bonilla v. Superior Court, County of Mendocino · No. 4:21-cv-01243
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows civil-rights claims against state actors. The cases involved various federal judges, state judges, court staff, and state and federal agencies. The complaints raised similar issues concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court.
The order identifies the following 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, 21-cv-01250-PJH, and 21-cv-01250-PJH. The opinion also states that Bonilla had a pending federal petition concerning his conviction with appointed counsel and was represented by counsel in state court proceedings.
Filing-fee restriction
Bonilla sought, or might have sought, permission to proceed without prepaying the filing fees. The court stated that he had already been disqualified from that status under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
Other legal barriers
The court further stated that, even if Bonilla’s request to proceed without prepaying fees were granted, the lawsuits would be barred under several doctrines and precedents. The order cited rules limiting civil-rights claims that would undermine an existing conviction, interfere with ongoing state proceedings, challenge certain federal court actions, or challenge bankruptcy court proceedings. The order did not provide a separate claim-by-claim analysis of each complaint.
Disposition
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. One complaint named Judge Hamilton as a defendant, but the order states that it made no specific allegations against her. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.