Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:21-cv-02049
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without fees and his claims faced additional legal bars.
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
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits against federal judges, state judges, and superior courts. He challenged his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying filing fees because of earlier qualifying dismissals, and his complaints did not show that he faced immediate danger when he filed them. The court also said that, even if he could proceed without fees, the lawsuits were barred by other legal rules.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was instructed to return any additional documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:21-cv-02049
- Phyllis Hamilton
- Mar. 29, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The complaints named various federal judges, state judges, and superior courts as defendants. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court.
The opinion also states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody, in which he has appointed counsel, and that he is represented by counsel in state-court proceedings.
Court’s analysis
The court ruled that Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), based on earlier cases identified in the opinion. The complaints also did not show that he was in immediate danger when he filed them, so he could not use the statutory exception to that filing-fee restriction.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would still be barred under the legal rules discussed in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and certain claims against federal courts or judges.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The opinion does not separately identify a disposition for individual claims within the complaints.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.