Bonilla v. White
- Phyllis Hamilton
- 4:24-cv-00851
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Clara Superior Court, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying and the suits faced legal barriers.
Steven Wayne Bonilla’s listed civil-rights cases were dismissed with prejudice; all pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
What happened
In Bonilla v. Santa Clara Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various federal and state judges. He sought relief concerning his conviction and the handling of his other state and federal court cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury. The complaints did not show such danger. The court also said that, even if he were allowed to proceed without paying, legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. It also rejected any suggestion that Judge Phyllis J. Hamilton should step aside because of Bonilla’s repetitive filings, and directed the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. White · No. 4:24-cv-00851
- Phyllis Hamilton
- Feb. 28, 2024
Background
Steven Wayne Bonilla, described as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. 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 state and federal courts handled his other cases.
The opinion also notes that Bonilla is a condemned prisoner with a pending federal petition challenging his detention in the same court, where he has appointed counsel. It further states that he is represented by counsel in state court proceedings concerning that petition. The opinion identifies the related proceedings by case numbers but does not describe their outcomes.
Filing-fee restriction and other bars
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in these cases without paying the filing fee unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the complaints did not show such danger.
The court added that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order relied on these filing restrictions and legal bars rather than deciding the underlying claims concerning Bonilla’s conviction or the handling of his cases.
Recusal issue
The court also addressed whether the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It concluded that these circumstances did not require the judge to step aside. The opinion states that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge. The court noted that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her.
Disposition
The court dismissed the cases 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 submitted in those closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.