Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:23-cv-05519
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and faced other legal barriers.
Steven Wayne Bonilla's multiple self-represented civil-rights cases were dismissed with prejudice. The clerk was directed to close them, terminate pending motions, and return later submissions without filing them.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. The lawsuits named federal judges and federal and state courts and challenged his conviction or the handling of his other cases.
Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his allegations did not show such danger. The court also said that, even if he could proceed without paying fees, the lawsuits would be barred by several legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:23-cv-05519
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government actors. He represented himself. The complaints presented nearly identical claims and named various federal judges and federal and state courts as defendants. The opinion says Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled. It also notes that he had a pending federal petition in this court with appointed counsel.
Filing-fee status
The court addressed Bonilla's ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show imminent danger at the relevant time, so he could not proceed without paying the fee.
Other stated barriers
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each rule's application to each complaint.
Ruling
Judge Phyllis J. Hamilton 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 stated basis for questioning the undersigned judge's impartiality, noting the repetitive and frivolous nature of the filings and the absence of a legitimate reason for recusal.
Scope and caption note
The supplied case name is “Bonilla v. Alameda County Superior Court,” while the opinion's displayed caption identifies the defendants as “JUDGE VINCE CHHABRIA et al.” and lists multiple case numbers. The summary uses the supplied case name and identifies the captioned defendants in the body.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.