Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:23-cv-03356
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and the suits faced legal bars.
Steven Wayne Bonilla and the multiple listed cases; the order also affects pending motions and any further documents submitted in those closed cases.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He challenged his conviction and the way other cases had been handled by state and federal courts.
The court said Bonilla could not file these cases without paying the filing fees because he had previously been barred from proceeding without those fees, and his complaints did not show that he faced an immediate risk of serious physical injury. The court also said that, even if he had been allowed to file without fees, legal rules cited in the order would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:23-cv-03356
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, identified as a state 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 handling of his other cases by state and federal courts.
Filing-fee ruling
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That restriction can be avoided only if the complaint shows that the prisoner was facing imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not make that showing. Bonilla therefore could not proceed without paying the filing fees.
Other legal barriers
The court further stated that, even if an application to proceed without paying fees had been 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 order did not reach the underlying merits of Bonilla’s challenges.
Disposition
The court dismissed the cases with prejudice. It also directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The court additionally rejected the claim that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.