Bonilla v. Superior Court, County of Sonoma
- Phyllis Hamilton
- 4:21-cv-01245
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla and the defendants named in the multiple cases, including federal judges, state judges, court staff, and state and federal agencies.
What happened
In Bonilla v. Superior Court, Steven Wayne Bonilla filed multiple civil-rights cases without a lawyer against federal and state judges, court staff, and state and federal agencies. His lawsuits challenged his conviction and how courts handled his other cases.
The court found that Bonilla could not proceed without paying the filing fees because he had not shown that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by other legal rules.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of Sonoma · No. 4:21-cv-01245
- Phyllis Hamilton
- Feb. 24, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal judges, state judges, court staff, and state and federal agencies as defendants. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction and the handling of his other state and federal court cases.
The order also noted that Bonilla had a pending federal petition challenging his conviction in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee ruling
The court addressed Bonilla’s requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore ruled that he could not proceed without paying the filing fees.
Other grounds cited
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under one or more of the legal doctrines or decisions cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately explain which doctrine applied to which case.
The court also addressed the fact that Bonilla named the presiding judge as a defendant in one case. It stated that the repetitive and allegedly frivolous nature of the filings did not create a reasonable question about the judge’s impartiality and cited the duty of a judge to handle assigned cases absent legitimate reasons for recusal.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to 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.