Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:23-cv-03332
- 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 paying and his claims faced legal bars.
Steven Wayne Bonilla and his multiple civil-rights cases against various federal and state judges were affected; the cases were dismissed with prejudice and closed.
What happened
In Bonilla v. U.S. District Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer against various federal and state judges. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he could proceed without fees, the lawsuits were blocked by several legal doctrines and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also rejected any concern that her impartiality could reasonably be questioned because of the repeated filings. The clerk was ordered to terminate the pending motions, close the cases, and return future documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:23-cv-03332
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, described 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 his other cases had been handled by state and federal courts.
The opinion states that Bonilla also had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning his custody. The cases addressed in this order were assigned multiple case numbers, including No. 23-cv-3305-PJH and the related cases listed in the caption.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.
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 the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
Impartiality and Case Closure
The court stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in those closed cases.
Disposition
Judge Phyllis J. Hamilton dismissed the multiple cases with prejudice, terminated the pending motions, and directed the clerk to close the cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.