Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:23-cv-01673
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Sonoma County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying other legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
What happened
In Bonilla v. Sonoma County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and county officials. The lawsuits sought relief related to his conviction and how other courts handled his cases.
The court found that Bonilla did not show an immediate danger of serious physical injury when he filed the complaints, so he could not proceed without paying filing fees. The court also said the lawsuits would be barred under several legal rules even if his fee applications were granted, and dismissed the cases with prejudice. The clerk was ordered to close the cases and return future filings without filing them.
Judge Phyllis J. Hamilton also rejected any concern that her impartiality could reasonably be questioned because Bonilla named her as a defendant in one case and had filed repetitive and frivolous actions. The order terminated all pending motions and closed the cases.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:23-cv-01673
- Phyllis Hamilton
- Apr. 14, 2023
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers the case numbers listed in the caption, including 23-cv-1282-PJH, 23-cv-1415-PJH, 23-cv-1416-PJH, 23-cv-1575-PJH, 23-cv-1576-PJH, 23-cv-1577-PJH, 23-cv-1579-PJH, 23-cv-1580-PJH, 23-cv-1581-PJH, 23-cv-1582-PJH, 23-cv-1625-PJH, 23-cv-1627-PJH, 23-cv-1667-PJH, 23-cv-1668-PJH, 23-cv-1669-PJH, 23-cv-1670-PJH, 23-cv-1671-PJH, 23-cv-1673-PJH, 23-cv-1728-PJH, 23-cv-1729-PJH, 23-cv-1730-PJH, 23-cv-1731-PJH, and 23-cv-1732-PJH.
Bonilla presented nearly identical claims and named various federal and state judges and county officials as defendants. The order says he sought relief concerning his underlying conviction or the way his other state and federal court cases had been handled. It also notes that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state court proceedings.
Filing-fee restriction
The court said Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed.
The court found that the complaints did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying fees 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 order did not separately analyze the application of each cited decision to each case.
Ruling
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The court addressed recusal, which is the process of removing a judge because impartiality might reasonably be questioned. Although Bonilla named Judge Phyllis J. Hamilton as a defendant in one case, the order said the repetitive and frivolous nature of the filings did not create a reasonable question about her impartiality. Judge 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.