Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:22-cv-05120
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Wilken, Judge Hamilton dismissed multiple cases with prejudice because Bonilla did not show imminent danger and the lawsuits were independently barred.
Steven Wayne Bonilla, a condemned state prisoner who filed the cases, was affected by the dismissals with prejudice, closure of the cases, termination of pending motions, and return of future submissions without filing. The order covered the related cases listed in the opinion.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges and state courts. In Bonilla v. Judge Wilken, he challenged his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he 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 those fees, the lawsuits were barred by other legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also declined to step aside, finding that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality. The clerk was directed to return future documents Bonilla submits in the closed cases without filing them.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:22-cv-05120
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named dozens of federal and state judges and various state courts as defendants, and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state proceedings concerning his custody.
Rulings
The court held that, to the extent Bonilla sought permission to proceed without paying filing fees, 28 U.S.C. § 1915(g) barred him from doing so unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the 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 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 dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in those closed cases.
Recusal request and final disposition
Bonilla named Judge Hamilton as a defendant in two of the cases. The court nevertheless concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. Citing the duty of a judge to decide assigned cases absent legitimate reasons for recusal, Judge Phyllis J. Hamilton declined to step aside.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.