Bonilla v. Lloyd
- Phyllis Hamilton
- 4:23-cv-03446
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and citing legal bars.
Steven Wayne Bonilla's multiple cases were dismissed with prejudice. The cases were closed, pending motions were terminated, and future documents submitted in those cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases under federal law against various federal and state judges. He challenged matters involving his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying filing fees because he had previously been barred from that procedure and did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal rules even if that permission were granted.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. It also ordered the clerk to return future documents Bonilla submitted in those closed cases without filing them. Judge Phyllis J. Hamilton additionally stated that the repetitive and frivolous filings did not provide a basis to question her impartiality.
The detailed version
- Bonilla v. Lloyd · No. 4:23-cv-03446
- Phyllis Hamilton
- July 28, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against government actors. The complaints were nearly identical and named various federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases.
The court noted that Bonilla had a pending federal petition challenging his conviction in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee status and legal bars
The court said Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the required filing fees, under 28 U.S.C. § 1915(g). He could proceed without paying only if he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
The court further stated that, even if Bonilla had been allowed to proceed without paying the filing fees, the lawsuits would be barred under several legal doctrines and authorities, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and challenges to court actions.
Ruling
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 the closed cases.
The court separately addressed its own impartiality, stating that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge's impartiality. The order was signed by Judge Phyllis J. Hamilton on July 28, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.