Bonilla v. Freeman
- Phyllis Hamilton
- 4:24-cv-02741
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple prisoner cases with prejudice because IFP was barred and other legal restrictions applied.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, and he could not proceed in those cases without paying the filing fee.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights cases while imprisoned. He sued various state courts and federal judges and sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from doing so unless he faced an immediate risk of serious physical injury. The court found that his complaints did not show that such a risk existed when he filed them. It also said that, even if he could proceed without paying, the lawsuits would be blocked by several legal rules concerning challenges to convictions, ongoing state proceedings, and suits against courts.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also ordered the clerk to return future documents Bonilla submitted in those closed cases without filing them. Judge Phyllis J. Hamilton rejected the suggestion that the repetitive filings required her to step aside.
The detailed version
- Bonilla v. Freeman · No. 4:24-cv-02741
- 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. The order covers the cases numbered 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.
The complaints presented nearly identical claims against various state courts and federal judges. Bonilla sought relief concerning his underlying conviction or the way other state and federal cases had been handled. The order also notes that he had a pending federal petition challenging his imprisonment, with appointed counsel, and was represented by counsel in state-court proceedings.
Inability to Proceed Without Paying the Filing Fee
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the filing fee, unless he showed that he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger at that time. Accordingly, Bonilla could not proceed without paying the filing fee.
Additional Bars Cited by the Court
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, which restricts certain civil-rights challenges that would undermine a conviction; Younger v. Harris, which limits federal interference with ongoing state proceedings; and Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court, which the order also cited as grounds barring the lawsuits. The order does not separately explain which cited bar applied to which individual case or claim.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in those closed cases.
The order separately addressed judicial impartiality. It stated that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. The court also noted that the judge was the fourth judge assigned to Bonilla’s cases and that this was the 63rd such filing.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton on May 29, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.