Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:23-cv-03340
- U.S. District Court · Northern District of California
- 3
In Bonilla v. San Benito County Superior Court, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without filing fees and his claims faced legal bars.
Steven Wayne Bonilla, who could not proceed in these cases without paying the filing fee and whose multiple lawsuits were dismissed with prejudice; the defendants named in those cases were also affected by the closures.
What happened
Bonilla v. San Benito County Superior Court involved multiple nearly identical civil-rights complaints by Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer. He sued various federal and state judges and sought relief connected to his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not show that danger. The court also said that, even if he were allowed to proceed without paying, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:23-cv-03340
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts. The opinion also states that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning such a petition.
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). That rule permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger. Accordingly, he could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules and decisions cited in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain how each cited authority applied to each case.
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 stated that the repetitive and frivolous nature of the filings did not provide a reason for the assigned judge to question her own impartiality. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.