Bonilla v. Superior Court of California County of Santa Cruz
- Phyllis Hamilton
- 4:22-cv-03248
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla and the multiple cases covered by the order; all pending motions were terminated, the cases were closed, and further documents submitted in them were to be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against dozens of federal and state judges, courts, and officials. He sought relief concerning his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed an imminent danger of serious physical injury. His complaints did not show that danger. The court also said the lawsuits would be barred even if he could proceed without paying fees, citing several legal doctrines and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Superior Court of California County of Santa Cruz · No. 4:22-cv-03248
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against state actors. The complaints were nearly identical. They named dozens of federal and state judges, state courts, and federal officials as defendants and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases. The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel.
Reasons for dismissal
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner with qualifying prior dismissals from proceeding without paying the fee unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying fees 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 did not provide a separate claim-by-claim analysis explaining which cited doctrine applied to which complaint.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. 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 court additionally rejected recusal based on the repetitive and allegedly frivolous nature of the filings, stating that no legitimate reason required the judge to step aside; a footnote noted that Bonilla named the judge as a defendant in one case but presented no legitimate basis for recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.