Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:24-cv-02714
- 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 showed no imminent danger and the lawsuits were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the defendants named in those cases were therefore not required to litigate the claims in those actions.
What happened
Steven Wayne Bonilla, a 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 said Bonilla could not proceed without paying the filing fees because he had previously been barred from fee-free filing and had not shown that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred even if fee-free filing were allowed.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:24-cv-02714
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple pro se 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 cases by state and federal courts.
The order covers the case numbers listed in the caption, 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.
Reasons for Dismissal
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying the filing fee, under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. The opinion also noted that Bonilla had an extensive history of filing similar frivolous cases.
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 rules and doctrines identified in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court did not decide the underlying challenges to Bonilla’s conviction or to the handling of his other cases.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also rejected the request for the judge’s recusal based on the repetitive and allegedly frivolous filings, stating that the circumstances did not reasonably call the judge’s impartiality into question.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.