Bonilla v. San Mateo County Superior Court
- Phyllis Hamilton
- 4:24-cv-02646
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed the cases with prejudice because Bonilla did not qualify for filing without prepaying fees and his claims were barred.
Steven Wayne Bonilla's multiple pro se civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return later documents submitted in them without filing.
What happened
Steven Wayne Bonilla v. Santa Cruz County Superior Court involved multiple nearly identical civil-rights cases filed by Bonilla, a condemned state prisoner representing himself. He sued various state courts and federal judges, seeking relief related to his conviction or the handling of his other cases.
The court said Bonilla was barred from filing without prepaying fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his allegations did not show such danger. It also said that, even if he could file without prepaying fees, the lawsuits were barred under several legal precedents.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. San Mateo County Superior Court · No. 4:24-cv-02646
- Phyllis Hamilton
- May 29, 2024
Background
Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion identifies him as a state prisoner and a condemned prisoner. He also had a pending federal petition challenging his confinement, for which he had appointed counsel, and he was represented by counsel in state-court proceedings concerning that petition.
The complaints presented nearly identical claims. Bonilla named various state courts and federal judges as defendants. The opinion says he sought relief concerning his underlying conviction or the way state and federal courts had handled his other cases.
Filing Without Prepaying Fees
The court explained that Bonilla had previously been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g). That provision permits a disqualified prisoner to proceed without prepaying fees only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations in these complaints did not show that Bonilla faced such an imminent danger. It therefore ruled that he could not proceed without prepaying filing fees.
Other Bars to the Lawsuits
The court further ruled that, even if Bonilla's applications to proceed without prepaying fees 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 opinion did not provide a separate claim-by-claim analysis of those authorities.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
The court additionally rejected the suggestion that the assigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of Bonilla's filings. The court noted that this was the fourth judge assigned to cases Bonilla had filed and that the opinion concerned his 63rd such case.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.