Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:24-cv-00381
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Del Norte Superior Court, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla’s related civil-rights lawsuits were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions in those closed cases without filing them.
What happened
In Bonilla v. Del Norte Superior Court, Steven Wayne Bonilla, a state prisoner, filed nearly identical civil-rights lawsuits without a lawyer against federal and state judges and state courts. He challenged his conviction and how other cases had been handled.
Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury. The court found that his complaints did not show such a risk. It also stated that, even if he could proceed without paying fees, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing proceedings, and court decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that future documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:24-cv-00381
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included various federal and state judges and state courts. The complaints sought relief concerning Bonilla’s underlying conviction and the way his other state and federal cases had been handled.
The order covered the cases listed in the caption, including Case Nos. 23-cv-6555-PJH, 24-cv-0018-PJH, 24-cv-0020-PJH, 24-cv-0021-PJH, 24-cv-0022-PJH, 24-cv-0029-PJH, 24-cv-0031-PJH, 24-cv-0367-PJH, 24-cv-0369-PJH, 24-cv-0381-PJH, 24-cv-0382-PJH, 24-cv-0383-PJH, 24-cv-0422-PJH, 24-cv-0423-PJH, 24-cv-0446-PJH, 24-cv-0453-PJH, 24-cv-0454-PJH, 24-cv-0455-PJH, 24-cv-0456-PJH, 24-cv-0458-PJH, 24-cv-0459-PJH, 24-cv-0460-PJH, and 24-cv-0461-PJH.
Filing-fee status
The court stated that Bonilla had already been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other grounds for dismissal
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 rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those grounds.
The court also addressed Bonilla’s naming of the presiding judge as a defendant in one case. It concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the judge’s impartiality and stated that the judge had a duty to decide cases assigned to her absent legitimate grounds for recusal.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.