Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:24-cv-00453
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Del Norte Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed under the fee-waiver rule and faced legal bars.
Steven Wayne Bonilla and the defendants named in the multiple cases were affected. The cases were closed, all pending motions were terminated, and future documents submitted in those closed cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Del Norte Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer. He sued various federal and state judges and state courts over his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury. The court found that his complaints did not show such a danger. It also said that, even if he could proceed under the fee-waiver rule, the lawsuits would be barred by several legal doctrines and prior decisions.
The court dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them. Judge Phyllis J. Hamilton also declined to recuse herself.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:24-cv-00453
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, identified by the court as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983 without a lawyer. The complaints asserted nearly identical claims against various federal and state judges and state courts. The court said Bonilla sought relief concerning his underlying conviction or the handling of his other state and federal cases. The opinion also noted that he had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Fee-waiver status
The court stated that Bonilla had been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show that Bonilla faced such danger at the time of filing. As a result, he could not proceed under that fee-waiver provision.
Other legal barriers
The court further stated that, even if a fee-waiver application had been granted, the lawsuits would be barred under the legal doctrines or decisions identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not analyze the individual claims further or decide whether those claims were legally valid on their merits.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Recusal issue
Bonilla named Judge Hamilton as a defendant in one of the cases. The court nevertheless concluded that the repetitive and frivolous nature of the filings did not create a reasonable question about the judge’s impartiality and therefore did not require recusal. The opinion also noted the large number of similar cases Bonilla had filed and orders concerning them.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.