Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:24-cv-01575
- U.S. District Court · Northern District of California
- 3
In Bonilla v. San Francisco County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla, whose multiple civil-rights cases were dismissed with prejudice, and the defendants named in those cases, including various federal and state judges.
What happened
In Bonilla v. San Francisco County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against various federal and state judges. He sought relief related to his conviction and the handling of his other court cases.
The court found that Bonilla could not proceed without paying the filing fee because he did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred under several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and directed the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:24-cv-01575
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal and state judges as defendants and presented nearly identical claims. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The order concerns the following case numbers: 24-cv-1206-PJH, 24-cv-1211-PJH, 24-cv-1486-PJH, 24-cv-1488-PJH, 24-cv-1490-PJH, 24-cv-1491-PJH, 24-cv-1492-PJH, 24-cv-1493-PJH, 24-cv-1494-PJH, 24-cv-1536-PJH, 24-cv-1565-PJH, 24-cv-1566-PJH, 24-cv-1567-PJH, 24-cv-1568-PJH, 24-cv-1569-PJH, 24-cv-1570-PJH, 24-cv-1571-PJH, 24-cv-1572-PJH, 24-cv-1574-PJH, 24-cv-1575-PJH, 24-cv-1689-PJH, 24-cv-1690-PJH, 24-cv-1709-PJH, 24-cv-1710-PJH, 24-cv-1711-PJH, and 24-cv-1854-PJH.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was under imminent danger of serious physical injury when he filed his complaint. The court found that the allegations did not show imminent danger at the relevant time. Therefore, Bonilla could not proceed without paying the filing fee.
Other grounds cited by the court
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 order also noted Bonilla's extensive history of filing similar cases.
Recusal issue
The court addressed the fact that Bonilla named the presiding judge as a defendant in three of the cases. It concluded that these cases were not ones in which the judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The court cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.