Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:23-cv-05397
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Humboldt County Superior Court, Judge Hamilton dismissed the cases with prejudice after finding Bonilla could not proceed without paying filing fees and that the suits were barred.
Steven Wayne Bonilla’s multiple self-represented civil-rights cases were dismissed with prejudice; the named federal judges and federal and state courts were defendants in those cases.
What happened
In Bonilla v. Humboldt County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints against federal judges and federal and state courts. He challenged his underlying conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by legal rules identified in the order.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated the pending motions, closed the cases, and directed the clerk to return future filings in those closed cases without filing them. She also found no basis to question her impartiality because of the repetitive and frivolous filings.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:23-cv-05397
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints while representing himself under 42 U.S.C. § 1983, a federal civil-rights law. The order addresses the cases listed under docket numbers 23-cv-4540-PJH, 23-cv-5164-PJH, 23-cv-5165-PJH, 23-cv-5278-PJH, 23-cv-5299-PJH, 23-cv-5300-PJH, 23-cv-5350-PJH, 23-cv-5389-PJH, 23-cv-5390-PJH, 23-cv-5391-PJH, 23-cv-5393-PJH, 23-cv-5394-PJH, 23-cv-5397-PJH, 23-cv-5398-PJH, 23-cv-5399-PJH, 23-cv-5400-PJH, 23-cv-5458-PJH, 23-cv-5459-PJH, 23-cv-5460-PJH, 23-cv-5465-PJH, 23-cv-5516-PJH, 23-cv-5517-PJH, 23-cv-5519-PJH, and 23-cv-5520-PJH. The complaints presented nearly identical claims against various federal judges and federal and state courts. Bonilla sought relief concerning his underlying conviction and the way other state and federal cases had been handled. The order also noted that he had a pending federal petition in the same court with appointed counsel.
Filing-fee status
Bonilla had previously been barred under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without prepaying the filing fee, unless he showed that he faced imminent danger of serious physical injury when he filed a complaint. The court held that the allegations in these complaints did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other grounds for dismissal
The court stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal authorities cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain which specific bar applied to which complaint.
Disposition
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. The court also concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question Judge Hamilton’s impartiality. A footnote states that Bonilla named the judge as a defendant in one case but presented no legitimate basis for recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.