Bonilla v. Superior Court of California, County of Humboldt
- Phyllis Hamilton
- 4:22-cv-03421
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple prisoner lawsuits with prejudice because Bonilla could not proceed IFP and the lawsuits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named federal and state judges, courts, and officials were no longer required to litigate these closed cases, and the clerk was directed not to file further documents Bonilla submitted in them.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits against judges, courts, and government officials. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate risk of serious physical injury, which his complaints did not show. The court also said that, even if he could proceed that way, the lawsuits were barred by several legal rules. It dismissed the cases with prejudice, meaning the dismissals ended these cases and the order did not permit refiling them.
Judge Phyllis J. Hamilton also rejected any suggestion that she should step aside because of the repetitive filings. She directed the clerk to terminate all pending motions, 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 Humboldt · No. 4:22-cv-03421
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law allowing claims against certain government actors for violating federal rights. The order covers the cases identified by the court as 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.
Bonilla named dozens of federal and state judges, state courts, and federal officials as defendants. The court described the complaints as presenting nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other cases. The order also noted that Bonilla had a pending federal petition in the same court with appointed counsel.
Reasons for dismissal
The court addressed Bonilla’s ability to proceed in forma pauperis, meaning without prepaying the filing fee. Under 28 U.S.C. § 1915(g), the court said he had been disqualified from proceeding in that manner unless he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger.
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
The court also addressed judicial impartiality. Although Bonilla named Judge Hamilton as a defendant in one of the cases, the court said the repetitive and frivolous nature of the filings did not provide a reason to question the judge’s impartiality. The court therefore did not step aside. The order was dated June 17, 2022, and signed by Judge Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.