Bonilla v. Superior Court of Monterey County
- Phyllis Hamilton
- 4:21-cv-02057
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without paying filing fees and his lawsuits were barred.
Steven Wayne Bonilla's multiple self-represented civil-rights cases were dismissed with prejudice; the court also closed the cases and directed the clerk not to file further documents submitted in them.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner, filed several civil-rights cases without a lawyer against federal judges, state judges, and superior courts. His complaints challenged his conviction and the handling of his habeas petitions and other court cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fee under a federal law covering repeat meritless filings. The complaints also did not show that he faced an immediate danger when he filed them. The court further said that, even if he could proceed without paying the fee, the lawsuits were barred by rules protecting existing convictions and ongoing court proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of Monterey County · No. 4:21-cv-02057
- Phyllis Hamilton
- Mar. 29, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases named various federal judges, state judges, and superior courts as defendants. The opinion identifies the cases by these docket numbers: 21-cv-02012-PJH, 21-cv-02013-PJH, 21-cv-02014-PJH, 21-cv-02049-PJH, 21-cv-02050-PJH, 21-cv-02052-PJH, 21-cv-02053-PJH, 21-cv-02056-PJH, 21-cv-02057-PJH, and 21-cv-02058-PJH.
Bonilla's complaints presented similar claims concerning his underlying conviction and the handling of his self-filed habeas petitions and other cases in state and federal court. The opinion also notes that he had a pending federal habeas petition with appointed counsel and was represented by counsel in state habeas proceedings.
Reasons for dismissal
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), a provision that limits fee-free filing by prisoners who have repeatedly filed cases that were dismissed as meritless or otherwise disqualified. The court found that the complaints did not show that Bonilla faced imminent danger when he filed them, so he could not proceed without paying the fee.
The court added that, even if a fee-free application had been granted, the lawsuits would have been barred under several authorities. Those included Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; and authorities concerning restrictions on challenges to federal court proceedings. The court did not conduct a merits determination in Bonilla's favor or against him on the underlying allegations.
Ruling and case status
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The court also stated that the clerk must terminate all pending motions and close the cases, and must return without filing any further documents Bonilla submits in the closed cases. The court separately rejected the suggestion that the judge's impartiality could reasonably be questioned because of Bonilla's repetitive and frivolous filings.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.