Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:24-cv-00369
- U.S. District Court · Northern District of California
- 3
Judge Hamilton dismissed Bonilla v. Del Norte Superior Court and related cases with prejudice, finding no imminent danger and several legal barriers to the lawsuits.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
In Bonilla v. Del Norte Superior Court and related cases, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights lawsuits against various federal and state judges and state courts. He sought relief concerning his conviction and how other cases were handled.
The court found that Bonilla could not proceed without paying the filing fees because he did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred by several legal rules even if his applications to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:24-cv-00369
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that permits claims against state actors for certain constitutional violations. He represented himself in these cases. The complaints were nearly identical and named various federal and state judges and state courts as defendants. They sought relief related to Bonilla’s underlying conviction and to the handling of his other cases in state and federal court.
The order covered the following case numbers: 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.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed a complaint. The court found that the allegations in these complaints did not show imminent danger at the relevant time. Therefore, Bonilla could not proceed without paying the fees.
Other Legal Bars
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis explaining which specific rule applied to which complaint.
The court also addressed the fact that Bonilla named Judge Hamilton as a defendant in one of the cases. It concluded that the repetitive and frivolous nature of the filings did not provide a valid reason to question the judge’s impartiality or require 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 directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.