Bonilla v. Monterey County Superior Corut
- Phyllis Hamilton
- 4:25-cv-00137
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill et al., Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and applicable legal bars.
The order directly affected Steven Wayne Bonilla's multiple civil-rights cases by dismissing them with prejudice and closing them. It also terminated all pending motions and directed the clerk to return further documents submitted in those closed cases.
What happened
In Bonilla v. Averill et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various federal and state judges and other officials. He sought relief concerning his conviction and the handling of his other cases in state and federal courts.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that status, and his allegations did not show that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and decisions.
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 further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Monterey County Superior Corut · No. 4:25-cv-00137
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law that allows certain claims for violations of constitutional rights by government officials. He represented himself in these cases. The complaints were nearly identical and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction and the way his state and federal court cases had been handled.
The court also noted that Bonilla was a condemned prisoner with a pending federal petition challenging his detention or conviction, in which he had appointed counsel, and that he was represented by counsel in state court proceedings.
Reasons for the ruling
The court addressed Bonilla's possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying 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 Bonilla's allegations did not show such danger, so he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion also noted Bonilla's extensive history of filing similar cases.
The court separately addressed whether the judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings. It concluded that these were not cases requiring the judge to step aside. The opinion noted that Bonilla named the judge as a defendant in four of the cases but made no specific allegations against her.
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 those closed cases. The order was signed by United States District Judge Phyllis J. Hamilton on January 30, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.