Bonilla v. Freeman
- Phyllis Hamilton
- 4:21-cv-02052
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the defendants named in the ten listed civil-rights cases, including various federal judges, state judges, and superior courts. The order also directed the clerk to close those cases and return future filings in them without filing.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases against federal judges, state judges, and superior courts. He challenged matters involving his conviction and the handling of his other cases and petitions.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from filing without them and had not shown immediate danger when he filed. The court also said the lawsuits would be barred by several legal rules even if he had been allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Freeman · No. 4:21-cv-02052
- Phyllis Hamilton
- Mar. 29, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The defendants included various federal judges, state judges, and superior courts. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his self-filed petitions and other cases in state and federal courts.
The opinion also noted that Bonilla had a pending federal petition challenging his conviction in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings. The court referred to those proceedings but did not decide them in this order.
Filing-fee status and barriers to the lawsuits
Bonilla sought, or appeared to seek, permission to proceed without paying the filing fees. The court said he was disqualified from that status under 28 U.S.C. § 1915(g), based on prior proceedings, unless he qualified for an exception. The court found that the complaints did not show he faced immediate danger when he filed them, so he could not proceed without paying.
The court added that, even if Bonilla had been allowed to proceed without paying, the lawsuits would be barred under the legal 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 rules.
Ruling and case administration
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings, stating that judges generally have a duty to decide assigned cases absent legitimate reasons for recusal.
Judge Phyllis J. Hamilton directed the clerk to terminate all pending motions and close the cases. The clerk was further directed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Effect of the order
The order ended the listed cases and barred refiling them as dismissed because the dismissal was expressly entered with prejudice. The opinion does not state whether Bonilla paid filing fees or filed any appeal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.