Bonilla v. Superior Court, County of Lake
- Phyllis Hamilton
- 4:21-cv-01641
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Desautels, Judge Hamilton dismissed Steven Wayne Bonilla’s multiple civil-rights cases with prejudice because he could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named federal judges, state judges, and superior courts were defendants in those cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against federal judges, state judges, and superior courts. The cases involved claims related to his conviction and his other challenges to it.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such a danger. It also said that, even if he could proceed without paying, the lawsuits would be barred under several legal doctrines and prior decisions cited in the order.
The court dismissed the cases with prejudice, meaning the dismissals were final under the order. Judge Phyllis J. Hamilton also directed the clerk to end pending motions, close the cases, and return future filings in them without filing them.
The detailed version
- Bonilla v. Superior Court, County of Lake · No. 4:21-cv-01641
- Phyllis Hamilton
- Mar. 22, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The defendants included federal judges, state judges, and superior courts. The complaints presented similar claims and sought relief concerning Bonilla’s underlying conviction or the way his other prisoner-release challenges were handled.
The order states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in related state proceedings. The court also noted that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed a complaint.
Court’s reasoning
The court found that the allegations in these complaints did not show an immediate danger of serious physical injury at the time of filing. As a result, Bonilla could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order does not explain separately how each cited doctrine applies to each individual case.
The court also rejected the apparent argument that the judge’s impartiality could reasonably be questioned because of Bonilla’s repeated filings. The order notes that Bonilla named the judge as a defendant in one case but did not make specific allegations against the judge in that complaint; the quoted opinion text ends before completing the footnote’s final sentence.
Disposition
The court dismissed the multiple 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. Judge Phyllis J. Hamilton signed the order on March 22, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.