Bonilla v. First Appellate District Court
- Phyllis Hamilton
- 4:24-cv-02983
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and other legal bars applied.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in those cases.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical lawsuits without a lawyer under a federal civil-rights law. He named various state courts and federal judges and sought relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he was disqualified from that fee waiver unless he faced an immediate danger of serious physical injury. The complaints did not show such danger. The court also said that, even if the fee waiver were granted, the lawsuits would be barred by other legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The clerk was also directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. First Appellate District Court · No. 4:24-cv-02983
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. The opinion describes Bonilla as a state prisoner and a condemned prisoner. He named various state courts and federal judges as defendants. The complaints sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The order covers numerous related case numbers, including 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.
Fee-waiver restriction
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was facing imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show that Bonilla faced such danger at the time of filing. Therefore, he could not proceed without paying the filing fees.
Other legal bars
The court further stated that, even if Bonilla's applications to proceed without paying 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 did not separately analyze each of those authorities or explain which one applied to each case.
The court also rejected the possibility that the assigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
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.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.