Bonilla v. San Mateo County Superior Court
- Phyllis Hamilton
- 4:24-cv-00455
- U.S. District Court · Northern District of California
- 3
Bonilla v. Del Norte Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and legal barriers.
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, and the defendants named in the multiple cases. The cases were dismissed with prejudice and closed.
What happened
In Bonilla v. Del Norte Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal and state judges and courts. He challenged his conviction and how other state and federal cases were handled.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to end all pending motions and close the cases. She also stated that the repetitive filings did not provide a reasonable basis to question her impartiality and directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. San Mateo County Superior Court · No. 4:24-cv-00455
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned 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 related 2024 case numbers. The complaints presented nearly identical claims against various federal and state judges and state courts.
Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal courts. The opinion also states that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
The court stated that Bonilla had previously been barred from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law allows a prisoner with the relevant filing history to 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 found that Bonilla’s allegations did not show imminent danger at the time of filing. It therefore ruled that he could not proceed without paying the filing fee.
Other legal barriers and disposition
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under rules and doctrines identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
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.
Impartiality issue
The court addressed whether the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings. The opinion stated that these cases did not provide such a basis. It also noted that Bonilla named the judge as a defendant in one of the cases but presented no legitimate reason for the judge to recuse herself.
Judge
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.