Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:23-cv-03336
- 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 after finding no imminent danger and other legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, and he could not proceed without prepaying the filing fee because the court found no imminent danger of serious physical injury. The named federal and state judicial defendants were affected by the closure of the cases, but the opinion does not impose a separate substantive judgment against them.
What happened
In Bonilla v. U.S. District Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He named various federal and state judges and sought relief concerning his conviction or how other cases had been handled.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from proceeding without prepayment unless he showed imminent danger of serious physical injury. The court found that his complaints did not show such danger when he filed them. It also said the lawsuits would be barred by other legal doctrines even if his applications to proceed without prepayment were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:23-cv-03336
- 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 cases had nearly identical claims. Bonilla named various federal and state judges as defendants and sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The opinion also states that he was a condemned prisoner with a pending federal habeas case and that he was represented by counsel in state-court habeas proceedings.
Filing-fee status
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without prepaying the filing fee unless he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show imminent danger at that time. Therefore, Bonilla could not proceed without prepaying the filing fee.
Other legal bars
The court further stated that, even if an application to proceed without prepayment were granted, the lawsuits would be barred under the doctrines or authorities identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim explanation of which cited bar applied to which case.
Ruling
The court dismissed the cases 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. The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. A footnote states that Bonilla named the judge as a defendant in one case but presented no legitimate reason for recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.