Bonilla v. Sixth Appellate District Court Judges
- Phyllis Hamilton
- 4:24-cv-00658
- 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 fee-waiver restrictions and legal bars applied.
Steven Wayne Bonilla and the defendants in the multiple listed cases, including various federal and state judges. The cases were dismissed with prejudice and closed.
What happened
In Bonilla v. Santa Clara Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against various federal and state judges. He sought relief concerning his conviction and the handling of other cases by state and federal courts.
The court found that Bonilla could not proceed without paying filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by rules and precedents the court cited.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Sixth Appellate District Court Judges · No. 4:24-cv-00658
- Phyllis Hamilton
- Feb. 28, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for violating federal rights. The complaints presented nearly identical claims and named various federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same district court, with appointed counsel, and was represented by counsel in state-court proceedings concerning his custody.
Fee-waiver restriction
The court stated that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. It therefore concluded that Bonilla could not proceed without paying the filing fees.
Other grounds identified by the court
The court further stated that, even if a fee-waiver application 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 conviction-related claims in Bonilla's favor or against him; it dismissed the cases based on the filing-fee restriction and the legal bars it identified.
Impartiality issue and disposition
The court also stated that the repetitive and frivolous nature of the filings did not create a situation in which the undersigned judge's impartiality could reasonably be questioned. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
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 opinion states that the undersigned judge was the fourth judge assigned cases filed by Bonilla and had issued an order concerning 800 different cases filed by him since April 30, 2020; it also states that Bonilla had filed 962 other cases with three other judges since 2011.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.