Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:24-cv-02643
- 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 because Bonilla could not proceed without prepaying the filing fee and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants named in those cases, including various state courts and federal judges, were affected by the closure of the cases.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer against state courts and federal judges. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla was barred from proceeding without prepaying the filing fee because his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he could proceed that way, the lawsuits would be barred for other legal reasons.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:24-cv-02643
- Phyllis Hamilton
- May 29, 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. 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 states that Bonilla had a pending federal petition challenging his conviction in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings concerning that petition.
Reasons for dismissal
The court addressed Bonilla’s ability to proceed without prepaying the filing fee, commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court said Bonilla was disqualified from proceeding in that manner unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger.
The court further stated that, even if an application to proceed without prepaying the filing fee were granted, the lawsuits would be barred under the legal rules identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion also noted Bonilla’s extensive history of filing similar cases.
Ruling and case closure
The court dismissed the cases with prejudice. 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.
The court separately rejected the suggestion that Judge Phyllis J. Hamilton’s impartiality could reasonably be questioned because of the 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. Judge Hamilton signed the order on May 29, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.