Bonilla v. Gonzalez-Rogers
- Phyllis Hamilton
- 4:24-cv-00020
- 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 fees and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights lawsuits were dismissed with prejudice, and he was barred from proceeding in them without paying filing fees because he did not show an immediate danger of serious physical injury.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against federal and state judges and state courts. He challenged his conviction and how other cases had been handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. The complaints did not make that showing. The court also said that, even if he were allowed to proceed without fees, legal rules would bar the lawsuits.
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 future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Gonzalez-Rogers · No. 4:24-cv-00020
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, a condemned state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal statute that allows certain civil-rights claims against state officials. The caption lists 23 related case numbers, beginning with 23-cv-6555-PJH. 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 court.
The opinion states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. It also states that he had an extensive history of filing similar cases.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze the claims under those rules.
Ruling
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 opinion additionally rejected any suggestion that Judge Hamilton's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It stated that Bonilla had named Judge Hamilton as a defendant in one case but had presented no legitimate reason for her recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.