Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:23-cv-01284
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and procedural rules barred them.
Steven Wayne Bonilla’s multiple § 1983 cases, the defendants named in those cases, and any further filings Bonilla attempted to submit in the closed cases.
What happened
In Steven Wayne Bonilla v. Court Clerk’s Office et al., Bonilla, a state prisoner, filed several nearly identical civil-rights lawsuits against federal and state judges and court officials. He sought relief involving courts.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that status and his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said that additional legal rules would bar the lawsuits even if he had been allowed to proceed without paying the fee.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future filings in them without filing them. Judge Phyllis J. Hamilton also concluded that the repetitive and frivolous filings did not provide a basis to question her impartiality.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:23-cv-01284
- Phyllis Hamilton
- Mar. 27, 2023
Background
Steven Wayne Bonilla, a state prisoner and condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints were filed in these related case numbers: 23-cv-0851-PJH, 23-cv-1071-PJH, 23-cv-1236-PJH, 23-cv-1275-PJH, 23-cv-1276-PJH, 23-cv-1278-PJH, 23-cv-1279-PJH, 23-cv-1280-PJH, 23-cv-1283-PJH, 23-cv-1284-PJH, 23-cv-1285-PJH, 23-cv-1286-PJH, 23-cv-1287-PJH, 23-cv-1331-PJH, 23-cv-1333-PJH, 23-cv-1355-PJH, and 23-cv-1356-PJH.
The complaints presented nearly identical claims and named various federal and state judges and court officials as defendants. Bonilla also had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings concerning a similar type of petition.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without prepaying the filing fee, under 28 U.S.C. § 1915(g). That restriction has an exception when a prisoner shows that he was in imminent danger of serious physical injury when he filed the complaint.
The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed in forma pauperis in these cases.
Additional Grounds for Dismissal
The court further stated that, even if an application to proceed without prepaying the filing fee 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 opinion did not provide a separate merits determination of Bonilla’s underlying claims.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases.
The court additionally concluded that the repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality. Judge Phyllis J. Hamilton cited the duty of a judge to handle assigned cases when no legitimate reason for recusal exists.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.