Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:23-cv-01671
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Humboldt County Superior Court, Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and identifying other legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, pending motions were terminated, and the cases were closed. The clerk was directed to return future documents submitted in those cases without filing them.
What happened
In Bonilla v. Humboldt County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against federal and state judges and county officials. He sought relief related to his conviction and the handling of his other court cases.
The court ruled that Bonilla could not proceed without paying filing fees because his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said that, even if he had been allowed to file without fees, the lawsuits were barred under several legal doctrines, and it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also rejected any suggestion that her impartiality could reasonably be questioned because of the repetitive filings. She directed the clerk to end all pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:23-cv-01671
- Phyllis Hamilton
- Apr. 14, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple pro se complaints under 42 U.S.C. § 1983. A pro se party represents himself or herself without a lawyer. The complaints presented nearly identical claims against various federal and state judges and county officials. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.
The opinion states that Bonilla had a pending federal petition challenging his detention, with appointed counsel, and was also represented by counsel in state-court proceedings. The opinion does not describe the individual allegations in each complaint separately.
Filing-fee restriction
The court addressed Bonilla's possible requests to proceed in forma pauperis, meaning to file without paying the ordinary filing fee. It stated that Bonilla had previously been disqualified from proceeding in that manner under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. Accordingly, Bonilla could not proceed without paying the filing fee.
Other legal bars and disposition
The court further stated that, even if a filing-fee application 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 does not specify which of these doctrines applied to which particular complaint. The court dismissed the cases with prejudice, using the court's express disposition.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.
Impartiality statement
The court stated that these were not cases in which the undersigned judge's impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. A footnote explains that Bonilla named the judge as a defendant in one case but presented no stated basis requiring the judge's recusal. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.