Bonilla v. San Mateo County Superior Court
- Phyllis Hamilton
- 4:21-cv-10016
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Mateo County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and the suits were otherwise barred.
Steven Wayne Bonilla’s multiple civil-rights cases, the defendants named in those cases, and any later filings in the closed cases.
What happened
In Bonilla v. San Mateo County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits seeking relief related to his conviction or the handling of other cases.
The court said Bonilla was barred from proceeding without paying filing fees because his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if his fee-waiver applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. San Mateo County Superior Court · No. 4:21-cv-10016
- Phyllis Hamilton
- Jan. 7, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims. The opinion says Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. It also notes that he had a pending federal petition concerning his imprisonment in this court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status and case barriers
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under the prisoner “three strikes” rule in 28 U.S.C. § 1915(g). That rule permits such a prisoner to proceed without paying only if the complaint shows that he was in immediate danger of serious physical injury when he filed it. The court found that these complaints did not show that kind of danger.
The court further stated that, even if a fee-waiver application were granted, 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 does not decide the underlying allegations about Bonilla’s conviction or the handling of his other cases.
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 additional documents Bonilla submitted in the closed cases. The opinion also stated that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question Judge Phyllis J. Hamilton’s impartiality. Bonilla had named the judge as a defendant in one case, but the court said that complaint made no specific allegations against her.
Classification basis
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal barriers rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.