Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:21-cv-02058
- U.S. District Court · Northern District of California
- 2
Bonilla v. Santa Cruz County Superior Court was dismissed with prejudice after Judge Hamilton found no imminent danger and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file additional documents submitted in them.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner, filed several civil-rights lawsuits without a lawyer against federal judges, state judges, and superior courts. His complaints concerned his conviction and how courts handled his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from proceeding without one, and his allegations did not show that he faced imminent danger when he filed. The court also said the lawsuits would be barred by other legal rules even if his request to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated the pending motions, closed the cases, and directed the clerk to return any additional documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:21-cv-02058
- Phyllis Hamilton
- Mar. 29, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal judges, state judges, and superior courts. The complaints presented similar claims seeking relief related to Bonilla’s underlying conviction and to the handling of his other petitions and cases in state and federal court.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was also represented by counsel in state-court proceedings. Those related proceedings were noted as background to the multiple civil-rights cases.
Court’s analysis
The court addressed Bonilla’s requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying unless the complaint shows imminent danger of serious physical injury. The court stated that Bonilla had already been disqualified from proceeding without paying under that provision and that his complaints did not show imminent danger at the time they were filed.
The court further stated that, even if Bonilla’s requests to proceed without paying were granted, the lawsuits would be barred by the rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. It cited the rule that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
The court dismissed the 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.