Bonilla v. Napa Superior Court its Judges and Clerks
- Phyllis Hamilton
- 4:23-cv-03355
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla and the defendants in his multiple civil-rights cases; the cases were dismissed with prejudice, pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
What happened
In Bonilla v. U.S. District Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges. He sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the 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 the lawsuits would be barred for other legal reasons even if his requests to proceed without paying were granted. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also concluded that the repetitive and frivolous filings did not provide a reason to question her impartiality. The clerk was directed to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Napa Superior Court its Judges and Clerks · No. 4:23-cv-03355
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his other cases. The opinion also notes that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings challenging his custody.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under the Prison Litigation Reform Act’s three-strikes rule, 28 U.S.C. § 1915(g). Under that rule, a prisoner with the relevant filing history may proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fees.
Other Bars and Disposition
The court further stated that, even if it granted Bonilla’s applications to proceed without paying fees, 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 analyze the underlying claims in detail; it relies on these stated filing and legal bars.
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 the closed cases.
Impartiality
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. Citing Ninth Circuit authority, Judge Phyllis J. Hamilton stated that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
Classification
This is a procedural order because the court disposed of the cases based on the filing-fee restriction and other legal bars rather than deciding whether Bonilla’s underlying civil-rights claims were legally valid.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.