Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:23-cv-03690
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Mendocino County Superior Court, Judge Hamilton dismissed multiple pro se civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla's multiple civil-rights lawsuits and the defendants named in those cases, including various federal and state judges.
What happened
In Bonilla v. Mendocino County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. He sued various federal and state judges and sought relief concerning his conviction and the handling of other court cases.
The court said Bonilla was barred from proceeding without paying the filing fee because he had previously been disqualified from that status and had not shown imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines and statutes.
The court dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them. Judge Phyllis J. Hamilton also rejected the apparent request for her recusal.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:23-cv-03690
- Phyllis Hamilton
- July 28, 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 order concerns the following case numbers: 23-cv-3304-PJH, 23-cv-3446-PJH, 23-cv-3447-PJH, 23-cv-3589-PJH, 23-cv-3590-PJH, 23-cv-3591-PJH, 23-cv-3592-PJH, 23-cv-3593-PJH, 23-cv-3686-PJH, 23-cv-3687-PJH, 23-cv-3688-PJH, 23-cv-3690-PJH, 23-cv-3691-PJH, 23-cv-3693-PJH, 23-cv-3694-PJH, and 23-cv-3695-PJH.
The court said the complaints presented nearly identical claims against various federal and state judges. Bonilla sought relief concerning his underlying conviction or the way other state and federal court cases had been handled. The order also noted that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status and dismissal grounds
The court addressed Bonilla's possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner previously disqualified from that status may proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had previously been disqualified and that these complaints did not show imminent danger at the relevant time. It therefore concluded that he could not proceed without paying the filing fee.
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 discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying civil-rights allegations in Bonilla's favor or against him; it dismissed the cases on filing-status and other threshold grounds.
Recusal and disposition
The court also addressed the fact that Bonilla named the presiding judge as a defendant in one case. It found that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question the judge's impartiality and did not require recusal.
The court dismissed the cases with prejudice. It 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 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.