Bonilla v. Superior Court, County of Humboldt
- Phyllis Hamilton
- 4:21-cv-01244
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his lawsuits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the defendants were no longer required to litigate those cases, and future documents in the closed cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights cases without a lawyer against federal and state judges, court staff, and government agencies. He challenged his conviction and the way courts handled his other cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury. The court found that his complaints did not show such a danger and said the lawsuits would also be barred by several legal rules even if he could proceed without paying fees.
The court dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future filings without filing them. Judge Phyllis J. Hamilton also declined to recuse herself because the filings did not provide a legitimate reason to question her impartiality.
The detailed version
- Bonilla v. Superior Court, County of Humboldt · No. 4:21-cv-01244
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. He named federal judges, state judges, court staff, and state and federal agencies as defendants. The complaints presented similar allegations concerning Bonilla’s underlying conviction and the handling of his pro se petitions and other cases in state and federal court.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings concerning that petition. The order covered 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 as listed in the opinion’s caption and text.
Court’s reasoning
The court explained that 28 U.S.C. § 1915(g) disqualifies a prisoner from proceeding in forma pauperis—meaning without paying the required filing fees—after qualifying prior cases, unless the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show imminent danger. The opinion also stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under rules identified in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
One case named Judge Hamilton as a defendant. The court concluded that the brief complaint made no specific allegations against her and that the repetitive and frivolous filings did not provide a legitimate reason to question her impartiality.
Ruling
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Classification
This is a procedural order. The court did not decide the underlying civil-rights allegations on their merits; it relied on Bonilla’s inability to proceed without paying filing fees and on threshold legal bars to the lawsuits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.