Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:24-cv-02631
- 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 did not qualify for fee-free filing and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
What happened
Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various state courts and federal judges. He challenged his conviction and how other state and federal cases had been handled.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that status and had not shown an immediate danger of serious physical injury when he filed. The court also said that, even if fee-free status were granted, legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases and return future filings in them without filing them.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:24-cv-02631
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple cases without a lawyer under 42 U.S.C. § 1983, a federal law allowing civil-rights claims against certain government actors. The cases named various state courts and federal judges as defendants. The opinion states that Bonilla presented nearly identical claims concerning his underlying conviction or the handling of his other cases in state and federal court.
The opinion also states that Bonilla is a condemned prisoner with a pending federal petition challenging his detention or conviction in the same district, where he has appointed counsel. He is also represented by counsel in state-court proceedings concerning that petition. The court noted Bonilla’s history of filing similar cases and stated that the judge was the fourth judge assigned cases filed by him and that this was the 63rd such matter.
Filing-fee status and legal barriers
The court addressed Bonilla’s request, to the extent he sought to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status generally cannot proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had been disqualified under that provision and that his allegations did not show such a danger at the time of filing.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate analysis of each rule’s application to each case.
Disposition
The court dismissed the cases with prejudice. The order also rejected any suggestion that the judge’s impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
Judge Phyllis J. 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.