Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:23-cv-01731
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Mendocino County Superior Court, Judge Hamilton dismissed multiple lawsuits with prejudice after finding no imminent danger and legal bars.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice; the named federal and state judges and county officials were defendants in those cases, and the clerk was ordered to close the cases and reject further filings in them.
What happened
In Bonilla v. Mendocino County Superior Court, Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against judges and county officials. He sought relief concerning his conviction or the handling of his other court cases.
The court ruled that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to close them and terminate all pending motions, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:23-cv-01731
- Phyllis Hamilton
- Apr. 14, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints named various federal and state judges and county officials. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his conviction or detention in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings seeking similar relief.
Court’s reasoning
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has previously accumulated qualifying dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court stated that Bonilla had been disqualified from proceeding without paying under that provision and that the allegations did not show imminent danger at the time of filing.
The court further stated that, even if an application to proceed without paying 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 did not separately analyze each doctrine’s application to each complaint.
The court also addressed impartiality. It concluded that these cases were not ones in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion notes that Bonilla named the judge as a defendant in one case but presented no legitimate reason 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 April 14, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.