Bonilla v. Hamilton
- Phyllis Hamilton
- 4:24-cv-00850
- U.S. District Court · Northern District of California
- 2
Bonilla v. Santa Clara Superior Court: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without a filing-fee waiver and the suits were independently barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the clerk was directed to close them and return later submissions without filing them.
What happened
In Bonilla v. Santa Clara Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights cases without a lawyer against various federal and state judges. He sought relief concerning his conviction and the handling of other cases.
The court ruled that Bonilla was disqualified from proceeding without paying the required filing fees unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said that, even if he had received a fee waiver, the lawsuits would be barred under several cited legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also ruled that the repetitive and allegedly frivolous filings did not provide a reasonable basis to question her impartiality. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Hamilton · No. 4:24-cv-00850
- Phyllis Hamilton
- Feb. 28, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases. The opinion identifies the related case numbers as 24-cv-0457-PJH, 24-cv-0607-PJH, 24-cv-0608-PJH, 24-cv-0609-PJH, 24-cv-0610-PJH, 24-cv-0629-PJH, 24-cv-0630-PJH, 24-cv-0658-PJH, 24-cv-0659-PJH, 24-cv-0820-PJH, 24-cv-0849-PJH, 24-cv-0850-PJH, 24-cv-0851-PJH, and 24-cv-1055-PJH.
The opinion states that Bonilla has a pending federal petition challenging his detention with appointed counsel and is represented by counsel in state-court proceedings. It also states that he has an extensive history of filing similar cases.
Reasoning
The court addressed Bonilla’s request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner disqualified by prior filings may proceed without paying the fee only if he was in immediate danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such danger.
The court further stated 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 opinion did not decide the underlying claims on their merits.
The court also rejected any basis for questioning Judge Hamilton’s impartiality based on the repetitive and allegedly frivolous nature of the filings. The opinion stated that, absent legitimate reasons for recusal, a judge has a duty to preside over assigned cases. A footnote stated 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. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Classification basis
This is a procedural order. The court dismissed the cases based on the prisoner filing-fee restriction and other threshold or legal-bar grounds without reaching the merits of Bonilla’s civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.