Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:23-cv-03335
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims faced legal bars.
Steven Wayne Bonilla’s multiple federal civil-rights cases were dismissed with prejudice; the cases were closed, pending motions were terminated, and later documents in those cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a prisoner representing himself, filed multiple nearly identical civil-rights lawsuits under federal law against various federal and state judges. He challenged his conviction and the way other state and federal court cases had been handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed. The complaints did not show that danger. The court also said the lawsuits would be barred under several legal rules and prior court decisions even if Bonilla had been allowed to proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:23-cv-03335
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court. The opinion also states that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning his custody.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if Bonilla had been allowed to proceed without paying the filing fee, the lawsuits would be barred under the legal rules and precedents identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also stated that the repetitive and allegedly frivolous filings did not create a reasonable question about the judge’s impartiality requiring recusal. A footnote states that Bonilla named Judge Hamilton as a defendant in one of the cases, although the provided opinion text cuts off before completing that explanation.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.