Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:24-cv-01567
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Lloyd, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not avoid filing fees and his claims were barred.
Steven Wayne Bonilla’s multiple listed cases were dismissed with prejudice and closed. Pending motions were terminated, and the clerk was directed to return future documents submitted in those cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Howard Lloyd and others, Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal and state judges. He challenged his conviction or how other cases had been handled by state and federal courts.
The court said Bonilla was barred from filing without paying fees unless he showed an immediate serious physical danger, which his complaints did not show. The court also said the lawsuits would be barred even if he were allowed to proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:24-cv-01567
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, identified as 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 his other cases had been handled by state and federal courts. The order lists numerous related case numbers, including 24-cv-1206-PJH, 24-cv-1211-PJH, 24-cv-1486-PJH, and others.
Filing-fee restriction
The court addressed Bonilla’s possible requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when it was filed. The court said Bonilla had already been disqualified from proceeding without paying fees under that provision and that these complaints did not show such a danger.
Other grounds cited by the court
The court further stated that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order also noted Bonilla’s extensive history of filing similar cases. It stated that the repetitive and allegedly frivolous filings did not provide a reasonable basis to question the undersigned judge’s impartiality, even though Bonilla named that judge as a defendant in three of the cases.
Disposition
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 order was signed by Judge Phyllis J. Hamilton.
Naming note
The supplied case name identifies Humboldt County Superior Court, but the opinion’s caption identifies the defendants as “JUDGE HOWARD LLOYD et. al.” This summary follows the opinion’s caption.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.