v. Bonilla
- Phyllis Hamilton
- 4:24-cv-02652
- 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 his claims faced legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also affected the various state courts and federal judges named as defendants by ending these cases and directing the clerk not to file further documents submitted in them.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer against various state courts and federal judges. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing proceedings, and court actions.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in the closed cases without filing them. Judge Phyllis J. Hamilton issued the order.
The detailed version
- v. Bonilla · No. 4:24-cv-02652
- 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 order covers the cases listed under Case Nos. 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.
Bonilla presented nearly identical claims in the cases. He named various state courts and federal judges as defendants and sought relief concerning his underlying conviction or the way other state and federal cases had been handled. The order also states that Bonilla had a pending federal habeas petition in the court with appointed counsel and was represented by counsel in state habeas proceedings.
Reasoning
The court addressed Bonilla's possible request to proceed in forma pauperis, meaning without prepaying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified under that statute may proceed without prepayment only if he was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified from proceeding in that manner and concluded that the allegations in these complaints did not show imminent danger at the time of filing.
The court further stated that, even if an application to proceed without prepaying the fee 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 order did not provide a separate claim-by-claim analysis of those barriers.
The court also rejected any suggestion that the 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 hear 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, and to return without filing any further documents Bonilla submitted in the 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.