Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:21-cv-10021
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Marin County, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice because Bonilla showed no imminent danger and the suits were legally barred.
Steven Wayne Bonilla and the defendants named in the multiple cases. The court closed the cases, terminated pending motions, and directed the clerk not to file further documents submitted in them.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under 42 U.S.C. § 1983. The complaints challenged his conviction or how state and federal courts handled his other cases.
The court ruled that Bonilla could not proceed without paying the required filing fees because he did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying those fees, the lawsuits were barred by several legal rules and prior decisions. The cases were dismissed with prejudice, and the clerk was ordered to close them and terminate pending motions.
Judge Phyllis J. Hamilton stated that her impartiality could not reasonably be questioned based on the repetitive and frivolous filings, including because Bonilla named her as a defendant in one case without making specific allegations against her. Judge Hamilton also directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:21-cv-10021
- Phyllis Hamilton
- Jan. 7, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, the federal civil-rights statute used to sue for certain violations carried out under state authority. The court said the complaints presented nearly identical claims seeking relief related to Bonilla’s underlying conviction or to the handling of his other cases by state and federal courts.
The opinion also noted 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 state-court proceedings concerning his custody. The opinion identified the federal matter as Bonilla v. Ayers, Case No. 08-0471 YGR, and the state matter as In re Bonilla, Case No. 20-2986 PJH, Docket No. 1 at 7.
Rulings
The court addressed Bonilla’s possible request to proceed without paying filing fees, commonly called proceeding in forma pauperis. It stated that Bonilla had previously been disqualified from doing so under 28 U.S.C. § 1915(g), unless he was facing imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the required fees.
The court further stated that, even if a fee-waiver application 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 court therefore dismissed the cases with prejudice. The order does not separately identify which cited legal rule applied to which individual case or claim.
Impartiality and Case Closure
The court stated that these cases did not present a situation in which Judge Phyllis J. Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. One complaint named Judge Hamilton as a defendant, but the court said that complaint made no specific allegations against her.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.