Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:22-cv-03422
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla's multiple self-represented civil-rights cases were dismissed with prejudice, and the cases were closed.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges, courts, and government officials. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because his allegations 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, the lawsuits were barred by several legal doctrines. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also rejected the concern that her impartiality could reasonably be questioned because of the repeated filings. She directed the clerk to end all pending motions, close the cases, and return any further documents without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:22-cv-03422
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named dozens of federal and state judges, various state courts, and federal officials. The opinion says Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. The opinion also notes that he had a pending federal petition challenging his custody in the same court with appointed counsel.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that these allegations did not show imminent danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other Legal Bars and Disposition
The court further stated that, even if an application to proceed without paying the filing fee 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 opinion does not separately explain which bar applied to which case. The court dismissed the cases with prejudice.
The court also addressed whether the judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It concluded that these were not cases in which the judge's impartiality could reasonably be questioned. A footnote states that Bonilla named the judge as a defendant in one case, but the available text of the footnote is incomplete.
Clerk's Instructions
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. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.