Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:21-cv-02012
- U.S. District Court · Northern District of California
- 2
Bonilla v. Santa Cruz County Superior Court was dismissed with prejudice because Bonilla could not proceed fee-free and his claims faced legal bars; Judge Hamilton ruled.
Steven Wayne Bonilla and the federal judges, state judges, and superior courts named as defendants in the multiple cases.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla filed multiple civil-rights lawsuits without a lawyer against federal judges, state judges, and superior courts. He challenged matters involving his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had been disqualified from fee-free filing and had not shown an immediate danger when he filed. The court also said the lawsuits would be barred even if he could proceed without fees, and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton declined to recuse herself, directed the clerk to terminate the pending motions and close the cases, and ordered that future documents in the closed cases be returned without filing.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:21-cv-02012
- Phyllis Hamilton
- Mar. 29, 2021
Background
Steven Wayne Bonilla, a state prisoner described in the order as condemned, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included various federal judges, state judges, and superior courts. 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 also noted that Bonilla had a pending federal petition concerning his imprisonment in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee determination
The court stated that Bonilla had already been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That rule permits a qualifying prisoner to proceed without the fee only in limited circumstances after certain prior cases, unless the complaint shows an imminent danger of serious physical injury. The court found that Bonilla’s allegations did not show imminent danger when he filed, so he could not proceed without paying the fee.
Other legal bars and disposition
The court further stated that, even if Bonilla’s applications to proceed without paying fees had been granted, the lawsuits would be barred under the legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice. The order did not reach the underlying truth of Bonilla’s allegations or grant relief concerning his conviction or other court proceedings.
Recusal and case closure
The court also determined that the repetitive and allegedly frivolous nature of the filings did not provide a valid reason to question the undersigned judge’s impartiality. Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. She further ordered the clerk to return, without filing, any additional documents Bonilla submitted in those closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.