Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:24-cv-00610
- 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 fees and the suits were barred.
Steven Wayne Bonilla and the multiple related civil-rights cases he filed. The cases were dismissed with prejudice, pending motions were terminated, and the clerk was directed to close the cases and return future documents submitted in them without filing.
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 challenged his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from filing cases without paying the filing fee unless he showed an immediate danger of serious physical injury. His complaints did not show that danger. The court also said that, even if he could proceed without paying the fee, the lawsuits would be barred by rules protecting criminal convictions and ongoing court proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases. The clerk was also ordered to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:24-cv-00610
- Phyllis Hamilton
- Feb. 28, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical and named various federal and state judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his other cases.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel and was represented by counsel in state-court proceedings. The court also noted his extensive history of filing similar cases.
Filing-fee restriction
To the extent Bonilla sought permission to proceed without paying the filing fee, the court applied 28 U.S.C. § 1915(g). That provision disqualifies a prisoner from proceeding without the fee after qualifying prior cases unless the prisoner was in 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 fee.
Other grounds for dismissal
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 civil-rights allegations on their merits.
Ruling and case administration
The court dismissed the cases with prejudice. It also concluded that the repetitive and allegedly frivolous filings did not provide a basis to reasonably question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The order was signed by Phyllis J. Hamilton, United States District Judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.