Bonilla v. First Appellate District Court Judges
- Phyllis Hamilton
- 4:23-cv-03333
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court, Judge Hamilton dismissed multiple complaints with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice and closed; pending motions were terminated, and later documents submitted in those closed cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints against various federal and state judges. He challenged his conviction or the way other state and federal cases had been handled.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury. His complaints did not show that danger. The court also said that, even if he could proceed without paying, several legal rules would bar the lawsuits.
The court dismissed all the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases. Judge Phyllis J. Hamilton also found no basis for questioning her impartiality, including because Bonilla named her as a defendant in one case without giving a legitimate reason for her disqualification.
The detailed version
- Bonilla v. First Appellate District Court Judges · No. 4:23-cv-03333
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, described in the opinion as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The cases had related docket numbers, including 23-cv-3305-PJH, 23-cv-3306-PJH, 23-cv-3307-PJH, 23-cv-3308-PJH, 23-cv-3309-PJH, 23-cv-3329-PJH, 23-cv-3331-PJH through 23-cv-3339-PJH, 23-cv-3340-PJH through 23-cv-3343-PJH, and 23-cv-3355-PJH through 23-cv-3359-PJH.
Bonilla presented nearly identical claims and named various federal and state judges as defendants. The opinion says he sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. It also states that he had a pending federal petition challenging his custody and was represented by counsel in state proceedings concerning his custody.
Reasons for dismissal
The court addressed Bonilla's possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying must show that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla's allegations did not show such a danger, so he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, which can limit civil-rights claims that would undermine a conviction; Younger v. Harris, concerning certain ongoing state proceedings; and two Ninth Circuit decisions concerning similar limits on suits against courts or judges. The opinion did not decide the underlying validity of Bonilla's conviction or the other courts' handling of his cases.
The court also considered whether its judge should be disqualified. Bonilla named Judge Hamilton as a defendant in one of the cases, but the court found no legitimate reason to question her impartiality and cited the general duty of a judge to decide assigned cases when no valid reason for disqualification exists.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and legal bars, without deciding the underlying challenges to Bonilla's conviction or to the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.