Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:24-cv-01494
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Howard Lloyd et al., Judge Hamilton dismissed the cases with prejudice because Bonilla showed no imminent danger and his claims were legally barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The defendants named in those lawsuits included various federal and state judges. The order also directs the clerk not to file further documents Bonilla submits in the closed cases.
What happened
In Bonilla v. Judge Howard Lloyd et al., Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer against various federal and state judges. He sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because he had not shown that he faced an immediate serious physical danger when he filed the complaints. The court also said that, even if he could proceed without paying, several legal rules barred his lawsuits.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:24-cv-01494
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, described by the court as a state prisoner and condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled. The court also noted that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that challenge.
Filing-fee status
The court addressed Bonilla’s possible requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when it was filed. The court stated that Bonilla had been disqualified under that provision and that his allegations did not show the required imminent danger.
Reasons for dismissal
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each complaint or explain in detail how each cited authority applied to each case. The court also rejected any suggestion that its judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings. The opinion noted that Bonilla named the undersigned judge as a defendant in three of the cases.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Classification
This is a procedural order. The court dismissed the cases based on Bonilla’s inability to proceed without paying under the prisoner-filing-fee rule and on threshold legal bars, rather than deciding the underlying claims about his conviction or the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.