Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:24-cv-00383
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Del Norte Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and his claims were barred.
Steven Wayne Bonilla and the defendants named in the multiple cases, including various federal and state judges and state courts; the clerk was directed to close the cases and reject later filings in them.
What happened
In Bonilla v. Del Norte Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under a federal law known as Section 1983. He sued various federal and state judges and state courts over his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he had previously been barred from proceeding without fees and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without fees, legal rules and prior decisions barred these lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:24-cv-00383
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The caption lists case number 23-cv-6555-PJH and numerous additional 2024 case numbers. The complaints presented nearly identical claims and named various federal and state judges and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court.
The opinion states that Bonilla had a pending federal petition challenging his detention in the same district with appointed counsel and was also represented by counsel in state-court proceedings. The court also noted his extensive history of filing similar cases.
Filing-fee restriction
The court explained that, under 28 U.S.C. § 1915(g), Bonilla had been disqualified from proceeding without paying the filing fee unless 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 imminent danger. It therefore ruled that Bonilla could not proceed without paying the filing fee.
Other grounds cited by the court
The court further stated that, even if an application to proceed without paying fees had been granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate analysis explaining which specific bar applied to which individual case or claim.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The court separately rejected the need for the judge to recuse herself, stating that the repetitive and allegedly frivolous nature of the filings did not create a reasonable question about her impartiality. Judge Phyllis J. Hamilton signed the order on January 29, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.