Bonilla v. Superior Court, County of San Benito
- Phyllis Hamilton
- 4:24-cv-02633
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and identifying multiple procedural bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also ended pending motions, closed the cases, and directed the clerk to return future documents submitted in those cases without filing them.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against state courts and federal judges. He challenged his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying filing fees because his complaints did not show that he faced an imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also declined to question her impartiality based on Bonilla’s repeated filings. She ordered the clerk to end pending motions, close the cases, and return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of San Benito · No. 4:24-cv-02633
- Phyllis Hamilton
- May 29, 2024
Background
Bonilla, identified as a state prisoner and condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. “Pro se” means he filed without a lawyer. The complaints presented nearly identical claims and named various state courts and federal judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.
The opinion also notes that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings. The cases listed in the order include Case Nos. 24-cv-2631-PJH, 24-cv-2632-PJH, 24-cv-2633-PJH, 24-cv-2634-PJH, 24-cv-2643-PJH, 24-cv-2644-PJH, 24-cv-2646-PJH, 24-cv-2647-PJH, 24-cv-2648-PJH, 24-cv-2649-PJH, 24-cv-2650-PJH, 24-cv-2651-PJH, 24-cv-2652-PJH, 24-cv-2712-PJH, 24-cv-2713-PJH, 24-cv-2714-PJH, 24-cv-2715-PJH, 24-cv-2741-PJH, 24-cv-2983-PJH, and 24-cv-3010-PJH.
Filing-fee restriction
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without prepaying the filing fee, unless he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger.
Other grounds cited by the court
The court further stated that, even if an application to proceed without prepaying fees 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 opinion does not provide a separate claim-by-claim explanation of how each cited decision applied to each complaint.
Disposition
The court dismissed the cases with prejudice. It also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The court cited the principle that, absent legitimate grounds for recusal, an assigned judge has a duty to decide the cases assigned to that judge.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Additional note
The opinion states that the undersigned was the fourth judge assigned cases filed by Bonilla and refers to an extensive history of similar frivolous cases. The supplied case name refers to the County of San Benito, while the opinion’s caption identifies the defendant as Santa Cruz County Superior Court.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.