Bonilla v. San Mateo County Superior Court
- Phyllis Hamilton
- 4:22-cv-05131
- U.S. District Court · Northern District of California
- 2
Bonilla v. San Mateo County Superior Court: Judge Hamilton dismissed Bonilla’s multiple civil-rights cases with prejudice because he could not proceed without paying and the lawsuits were barred.
Steven Wayne Bonilla, who filed the cases, and the federal and state judges and state courts he named as defendants.
What happened
In Bonilla v. San Mateo County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. He challenged his conviction and the handling of his other cases, naming many federal and state judges and state courts as defendants.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The court also said its impartiality could not reasonably be questioned because of the repetitive and frivolous filings, and directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. San Mateo County Superior Court · No. 4:22-cv-05131
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer 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 other state and federal court cases had been handled.
The opinion identifies the cases by multiple docket numbers: 22-cv-4905-PJH, 22-cv-4971-PJH, 22-cv-4999-PJH, 22-cv-5010-PJH, 22-cv-5074-PJH, 22-cv-5076-PJH, 22-cv-5078-PJH, 22-cv-5120-PJH, 22-cv-5125-PJH, 22-cv-5127-PJH, 22-cv-5129-PJH, 22-cv-5130-PJH, and 22-cv-5131-PJH. The opinion also states that Bonilla had a pending federal petition challenging his detention or conviction with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without the Filing Fee
The court addressed whether Bonilla could proceed in forma pauperis, meaning without paying the filing fee. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without the fee unless he was facing imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show imminent danger at that time.
Other Bars Identified by the Court
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 provide a separate analysis of how each cited decision applied to each complaint.
The court also rejected any suggestion that the assigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. A footnote states that Bonilla named the judge as a defendant in two of the cases but presented no legitimate basis for recusal.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order on September 12, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.