Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:23-cv-01667
- U.S. District Court · Northern District of California
- 3
In Bonilla v. San Francisco County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the named federal and state judges and county officials were defendants in those cases.
What happened
In Bonilla v. San Francisco County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer under a federal law allowing suits against officials. He named various federal and state judges and county officials and sought relief concerning his conviction and how other cases were handled.
The court said Bonilla could not proceed without paying filing fees because his allegations did not show that he faced immediate danger of serious physical injury when he filed the lawsuits. The court also said that, even if he were allowed to proceed without fees, several legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them. The judge also concluded that recusal was not required based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:23-cv-01667
- Phyllis Hamilton
- Apr. 14, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a prisoner under a death sentence, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the case numbers listed in its caption. Bonilla presented nearly identical claims and named various federal and state judges and county officials as defendants. He sought relief concerning his underlying conviction or the handling of his other state and federal court cases.
The order states that Bonilla had a pending federal petition challenging his custody in this court, with appointed counsel, and was also represented by counsel in state-court proceedings concerning that petition.
Reasons for Dismissal
The court addressed Bonilla's ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without fees only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger.
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal doctrines and authorities cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order therefore dismissed the cases with prejudice.
Other Ruling and Disposition
The court also concluded that the cases did not require the judge to step aside because the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the judge's impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
This is a procedural order because the court dismissed the cases based on filing-fee restrictions and threshold legal bars rather than deciding the underlying challenges to Bonilla's conviction or the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.