Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:24-cv-01569
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Lloyd, Judge Hamilton dismissed the cases with prejudice because Bonilla showed no imminent danger and faced other legal barriers.
Steven Wayne Bonilla, who filed the cases without a lawyer, was affected by the dismissal with prejudice, the denial of permission to proceed without paying filing fees, and the closure of the cases. The named federal and state judge defendants were affected because the cases against them were closed.
What happened
Steven Wayne Bonilla v. Judge Howard Lloyd et al. involved multiple nearly identical civil-rights lawsuits filed by Bonilla, a state prisoner representing himself. He sued various federal and state judges over his conviction and how other court cases were handled.
Bonilla sought permission to proceed without paying filing fees. The court said he was barred from doing so unless he showed that he faced imminent danger of serious physical injury when he filed, and his complaints did not make that showing.
Judge Phyllis J. Hamilton also ruled that the lawsuits would be barred even if fee permission were granted. She dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future documents in those cases without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:24-cv-01569
- Phyllis Hamilton
- Mar. 27, 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 certain government officials. The cases named various federal and state judges as defendants. The court said the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The court also noted that Bonilla had a pending federal habeas matter and was represented by counsel in state-court habeas proceedings. The opinion stated that Bonilla had an extensive history of filing similar cases.
Filing-fee restriction
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that he was disqualified under 28 U.S.C. § 1915(g). That provision prevents a prisoner with the relevant filing history from proceeding without paying the fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show imminent danger at that time.
Other legal barriers and ruling
The court further stated that, even if Bonilla’s request to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those grounds.
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. The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.