Bonilla v. County of Alameda Superior Court
- Phyllis Hamilton
- 4:24-cv-02712
- 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 could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; pending motions were terminated, the cases were closed, and later documents in those closed cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Santa Cruz County Superior Court et al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases under federal law. 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 was barred from proceeding without prepaying 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 prepaying fees, the lawsuits were barred under several legal doctrines identified in the order.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any additional documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. County of Alameda Superior Court · No. 4:24-cv-02712
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints representing himself under 42 U.S.C. § 1983, the federal civil-rights statute. The order covers multiple cases, including 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.
The complaints asserted nearly identical claims against various state courts and federal judges. The order says Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. It also notes that he had a pending federal petition concerning his conviction in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee restriction
Bonilla sought, or could have sought, permission to proceed in forma pauperis, meaning without prepaying the filing fee. The court said he had been disqualified from doing so under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints.
The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without prepaying the filing fee.
Other grounds cited by the court
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 legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those grounds.
The court also rejected any suggestion that the presiding judge's impartiality could reasonably be questioned because of Bonilla's repetitive and frivolous filings. Citing Ninth Circuit authority, the court stated that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification basis
This is a procedural order. The court ended the cases based on Bonilla's inability to proceed without prepaying filing fees and on threshold legal barriers identified in the order, rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.