Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:24-cv-01536
- U.S. District Court · Northern District of California
- 3
Bonilla v. Judge Howard Lloyd, Judge Hamilton dismissed multiple civil-rights cases with prejudice after denying fee waiver eligibility and finding additional legal barriers.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the named federal and state judge defendants were not required to litigate the claims.
What happened
In Steven Wayne Bonilla v. Judge Howard Lloyd et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal and state judges. He sought relief concerning his conviction and how other cases were handled.
The court said Bonilla could not proceed without paying filing fees because he had previously been barred from using the fee-waiver process and had not shown an imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred even if fee waivers were available because of several legal rules protecting ongoing proceedings and criminal judgments.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to return without filing any further documents submitted in the closed cases.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:24-cv-01536
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical and named various federal and state judges as defendants. The court said Bonilla sought relief concerning his underlying conviction or the handling of his other cases in state and federal court. The opinion also states that he had a pending federal petition challenging his detention and was represented by counsel in state-court proceedings concerning that petition.
Fee-waiver eligibility
The court considered whether Bonilla could proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant filing history may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified from proceeding without paying fees under that provision. It found that the allegations did not show imminent danger at the time of filing.
Other legal barriers
The court further stated that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under the 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 decide the underlying validity of Bonilla’s conviction or the merits of his claims against the judges.
Ruling and case administration
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The court also concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the judge’s impartiality. The opinion states that Bonilla named Judge Hamilton as a defendant in three of the cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.