Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:24-cv-01566
- U.S. District Court · Northern District of California
- 3
Bonilla v. Del Norte County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after denying fee-free status and finding the lawsuits legally barred.
Steven Wayne Bonilla and the defendants named in his multiple cases, including various federal and state judges; the cases were closed and future submissions in them were to be returned without filing.
What happened
In Bonilla v. Del Norte County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases against various federal and state judges. He challenged matters involving his conviction and how other cases were handled.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from fee-free filing, and his complaints did not show an immediate risk of serious physical injury. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:24-cv-01566
- 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. The cases named various federal and state judges as defendants. The complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts. The order covered the case numbers listed in the caption, including 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 through 24-cv-1575-PJH, 24-cv-1689-PJH, 24-cv-1690-PJH, and 24-cv-1709-PJH through 24-cv-1711-PJH, as well as 24-cv-1854-PJH.
Fee-free filing status
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.
Other legal bars
The court further stated that, even if a fee-free application 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 did not provide a separate claim-by-claim analysis explaining which cited bar applied to which complaint.
Recusal issue
The court also rejected the apparent suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. Citing Ninth Circuit authority, the court stated that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases. A footnote stated that Bonilla named the judge as a defendant in three of the cases.
Disposition
The court dismissed the cases 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 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.