Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:23-cv-03341
- U.S. District Court · Northern District of California
- 3
Bonilla v. Santa Cruz County Superior Court: Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The clerk was directed to terminate pending motions, close the cases, and return without filing any further documents submitted in them.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights complaints against various federal and state judges. He challenged his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from that status, and his complaints did not show an imminent danger of serious physical injury when filed. The court also said that, even if he were allowed to proceed without paying, his lawsuits would be barred by several legal rules concerning challenges to convictions, interference with ongoing proceedings, and suits against courts or judges.
Judge Hamilton ordered that the cases be dismissed with prejudice, terminated all pending motions, and closed the cases. The clerk was also directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:23-cv-03341
- 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 order covers the following cases: Nos. 23-cv-3305-PJH, 23-cv-3306-PJH, 23-cv-3307-PJH, 23-cv-3308-PJH, 23-cv-3309-PJH, 23-cv-3329-PJH, and 23-cv-3331-PJH through 23-cv-3343-PJH, as well as Nos. 23-cv-3355-PJH through 23-cv-3359-PJH.
The complaints were described as nearly identical. Bonilla named various federal and state judges as defendants and sought relief concerning his underlying conviction or the way other cases had been handled by state and federal courts. The order also states that he is a condemned prisoner with a pending federal petition challenging his custody and that he is represented by counsel in state custody-related proceedings.
Reasoning
The court said Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several legal doctrines and precedents, including rules limiting civil-rights challenges to criminal convictions, federal interference with certain ongoing proceedings, and claims against federal courts or judges.
The order also addressed the judge’s impartiality, stating that the cases were not ones in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. A footnote states that Bonilla named the judge as a defendant in one of the cases.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.