Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:22-cv-05129
- U.S. District Court · Northern District of California
- 2
Bonilla v. Judge Wilken: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice, and the listed federal and state judges and courts were no longer required to litigate those closed cases.
What happened
In Bonilla v. Judge Wilken, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against numerous federal and state judges and courts. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had been barred from proceeding without payment unless he showed an immediate risk of serious physical injury, which his complaints did not show. The court also said that, even if he had been allowed to proceed without payment, the lawsuits would be barred by several legal doctrines protecting ongoing proceedings, convictions, and judicial decisions. The court dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future filings in them without filing them.
Judge Phyllis J. Hamilton also declined to recuse herself, explaining that the repetitive and frivolous filings did not provide a reason to question her impartiality. The order was dated September 12, 2022.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:22-cv-05129
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were described as 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 was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings.
Court’s reasoning
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Therefore, 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 had been 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 opinion did not provide a separate claim-by-claim analysis of those doctrines.
Disposition
The court dismissed the cases with prejudice. 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.
Judge Phyllis J. Hamilton declined to recuse herself. The court stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the judge’s impartiality. The opinion notes that Bonilla named the judge as a defendant in two of the cases but did not present a legitimate reason for recusal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.