Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:24-cv-02647
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla’s 20 listed civil-rights cases were dismissed with prejudice and closed. The defendants named in those cases were state courts and federal judges. The clerk was ordered to return future documents Bonilla submitted in those closed cases without filing them.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under federal law. He challenged his conviction and the way state and federal courts handled his other cases, naming various state courts and federal judges as defendants.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from filing without fees unless he showed imminent danger of serious physical injury. The allegations did not show that danger. The court also said that, even if he could proceed without fees, legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. It also ordered the clerk to return future documents Bonilla submitted in those closed cases without filing them. Judge Hamilton rejected the suggestion that the repetitive filings created a reasonable question about her impartiality.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:24-cv-02647
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed 20 civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various state courts and federal judges as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases. The opinion also noted that Bonilla had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings.
Proceeding Without Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That rule allows a disqualified prisoner to proceed without fees only when the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such imminent danger. Therefore, Bonilla could not proceed without fees in these cases.
Other Legal Bars
The court further stated that, even if an application to proceed without fees were granted, 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 court relied on those barriers rather than deciding whether Bonilla’s challenges to his conviction or to the handling of his other cases had merit.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The court separately addressed impartiality. It concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. Citing precedent, the court said that, absent legitimate grounds for disqualification, a judge has a duty to decide cases assigned to that judge.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.