Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:22-cv-06056
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Imperial County Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple cases were dismissed with prejudice. The order also affected the numerous county clerks and federal judges named as defendants by ending the cases, and directed the court clerk to close them and return later submissions without filing them.
What happened
In Bonilla v. Imperial County Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under a federal law governing claims against government officials. He challenged his conviction and the handling of his other state and federal court cases. The complaints named numerous county clerks and federal judges as defendants.
The court said Bonilla had previously been barred from filing cases without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury. The court found that his allegations did not show such a danger. It also said that, even if he could proceed without paying the fee, the lawsuits were barred by several legal doctrines.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also directed the clerk to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton further ruled that recusal was not required based on the repetitive and frivolous nature of the filings.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:22-cv-06056
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order lists numerous related case numbers. Bonilla is described as a state prisoner facing a death sentence. He also had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state-court proceedings challenging his conviction.
The complaints were nearly identical. They named numerous county clerks and federal judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
Filing-fee status and legal barriers
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee, unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. The court therefore ruled that Bonilla could not proceed without paying the fee.
The court added that, even if Bonilla had been allowed to proceed without paying the fee, the lawsuits would be barred under the legal doctrines 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. 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 the closed cases.
The court separately considered whether Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It concluded that these circumstances did not require her to step aside. The order was signed by Phyllis J. Hamilton, United States District Judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.