v. Bonilla
- Phyllis Hamilton
- 4:24-cv-00382
- 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 after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named federal and state judges and state courts were defendants in those cases.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints without a lawyer against federal and state judges and state courts. He sought relief concerning his underlying conviction and the handling of other cases.
The court found that Bonilla could not proceed without paying filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying fees, legal rules identified in the order would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submits in those closed cases be returned without filing.
The detailed version
- v. Bonilla · No. 4:24-cv-00382
- 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 allows certain claims against government actors. He filed the complaints without a lawyer. The order covers the case numbers listed in the caption, including 23-cv-6555-PJH and numerous related 2024 cases.
Bonilla named various federal and state judges and state courts as defendants. The court said that the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases. The order also noted that Bonilla had a pending federal petition challenging his detention or conviction with appointed counsel and was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying fees 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 such danger, so he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules and authorities identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court also stated that Bonilla had an extensive history of filing similar frivolous cases.
The order additionally rejected the apparent basis for questioning Judge Hamilton’s impartiality based on the repetitive and frivolous filings. It stated that the cases were not ones in which her impartiality might reasonably be questioned. The order notes that Bonilla named Judge Hamilton as a defendant in one case, but the quoted opinion text does not provide the remainder of that footnote’s explanation.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submits in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.