Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:23-cv-03331
- 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 file without prepaying fees and his claims faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and he was barred from proceeding without prepaying filing fees because the complaints did not show imminent danger.
What happened
In Bonilla v. U.S. District Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He challenged his conviction or the way other cases had been handled.
Bonilla sought to proceed without prepaying filing fees, but the court said he could not use that procedure unless he showed an imminent danger of serious physical injury when he filed. The court found no such danger. It also said the lawsuits would be barred by other legal rules even if he could proceed without prepaying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that future documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:23-cv-03331
- Phyllis Hamilton
- July 12, 2023
Background
Steven Wayne Bonilla, a state prisoner and 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 handling of his other cases by state and federal courts.
The order covers the following related case numbers: 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, 23-cv-3332-PJH, 23-cv-3333-PJH, 23-cv-3334-PJH, 23-cv-3335-PJH, 23-cv-3336-PJH, 23-cv-3337-PJH, 23-cv-3338-PJH, 23-cv-3339-PJH, 23-cv-3340-PJH, 23-cv-3341-PJH, 23-cv-3342-PJH, 23-cv-3343-PJH, 23-cv-3355-PJH, 23-cv-3356-PJH, 23-cv-3357-PJH, 23-cv-3358-PJH, and 23-cv-3359-PJH.
Filing-fee determination
The Prison Litigation Reform Act generally prevents a prisoner who has accumulated qualifying prior dismissals from proceeding without prepaying the filing fee, unless the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without prepaying fees under 28 U.S.C. § 1915(g). It found that the complaints did not show imminent danger at the time of filing, so Bonilla could not proceed under that exception.
Other legal bars
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately explain which cited rule applied to which complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
The order noted that Bonilla named Judge Hamilton as a defendant in one of the cases. It nevertheless rejected the suggestion that the repetitive and frivolous filings created a reasonable basis to question the judge’s impartiality. Judge Hamilton signed the order on July 12, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.