Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:23-cv-05465
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also prevents him from proceeding without paying filing fees under the stated prisoner-filing restriction and directs the clerk to close the cases.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits. He sued various federal judges and federal and state courts, seeking relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he showed an imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate 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. Santa Cruz County Superior Court · No. 4:23-cv-05465
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers numerous related case numbers. The complaints were nearly identical and named various federal judges and federal and state courts as defendants. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The order also states that he had a pending federal petition challenging his imprisonment in the same court, with appointed counsel.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if the complaint shows that he was in imminent danger of serious physical injury when he filed it. The court found that the allegations did not show imminent danger. Bonilla therefore could not proceed without paying the filing fee.
Other legal bars
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 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 provide a separate claim-by-claim explanation of how each cited rule applied.
Recusal issue and disposition
The court rejected the suggestion that the undersigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The order noted that Bonilla named the judge as a defendant in one case but did not provide a further recusal basis in the text provided.
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 the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.