Bonilla v. Hamilton
- Phyllis Hamilton
- 4:24-cv-01055
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Clara Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and legal bars applied.
Steven Wayne Bonilla and the defendants in the related civil-rights cases; the cases were dismissed with prejudice and closed.
What happened
In Steven Wayne Bonilla v. Santa Clara Superior Court and related cases, Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He sought relief concerning his conviction and the handling of other cases in state and federal courts.
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 when he filed. The complaints did not make that showing. The court also said that, even if Bonilla could proceed without paying fees, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Hamilton · No. 4:24-cv-01055
- Phyllis Hamilton
- Feb. 28, 2024
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion describes Bonilla as a state prisoner and a condemned prisoner proceeding without a lawyer in these cases. He has a pending federal petition challenging his custody in the same district with appointed counsel, and he is represented by counsel in state-court proceedings concerning that petition.
The complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
Filing-fee status and other barriers
To the extent Bonilla sought permission to proceed without prepaying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was under an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.
The court further stated that, even if Bonilla’s request to proceed without prepaying fees were granted, the lawsuits would be barred under the rules and decisions identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying validity of Bonilla’s civil-rights allegations.
Recusal issue and disposition
The court also stated that the cases did not present a basis to question the undersigned judge’s impartiality because of the repetitive and allegedly frivolous nature of the filings. It noted that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The order was signed by Judge Phyllis J. Hamilton.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and threshold legal bars without reaching the merits of the civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.