Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:22-cv-03276
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the named federal and state judges, courts, and officials were defendants.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal and state judges, courts, and officials. He sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla did not show he was in imminent danger of serious physical injury when he filed the complaints. Because he had already been barred from proceeding without paying the filing fee under the applicable law, he could not proceed that way. The court also said the cases would be barred by other legal rules even if he were allowed to proceed without paying, and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton declined to recuse herself, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:22-cv-03276
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical and named dozens of federal and state judges, state courts, and federal officials as defendants. Bonilla sought relief concerning his underlying conviction and the way state and federal courts handled his other cases. The order covers multiple cases, including Case Nos. 22-cv-1900-PJH, 22-cv-2674-PJH, 22-cv-2776-PJH, 22-cv-2871-PJH, 22-cv-2872-PJH, 22-cv-3247-PJH, 22-cv-3248-PJH, 22-cv-3275-PJH, 22-cv-3276-PJH, 22-cv-3318-PJH, 22-cv-3319-PJH, 22-cv-3322-PJH, 22-cv-3421-PJH, 22-cv-3422-PJH, 22-cv-3423-PJH, 22-cv-3424-PJH, 22-cv-3425-PJH, 22-cv-3445-PJH, 22-cv-3446-PJH, 22-cv-3447-PJH, 22-cv-3448-PJH, 22-cv-3449-PJH, and 22-cv-3450-PJH.
Filing-fee restriction and dismissal
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
Recusal and case closure
The court also addressed whether Judge Phyllis J. Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The order stated that this was not a basis for recusal. A footnote noted that Bonilla named Judge Hamilton as a defendant in one case but did not provide a legitimate reason for recusal.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.