Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:22-cv-03247
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Marin County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after denying permission to proceed without fees.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, and the named defendants were no longer required to litigate those cases in the district court.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges, courts, and government officials. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an immediate serious physical danger, and his complaints did not show that danger. The court also said that other legal rules would bar the lawsuits even if he were allowed to proceed without fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that future documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:22-cv-03247
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion lists numerous related case numbers, including 22-cv-1900-PJH and 22-cv-2674-PJH through 22-cv-3450-PJH. The complaints were nearly identical. Bonilla named dozens of federal and state judges, state courts, and federal officials as defendants. The opinion says he sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. He also had a pending federal petition challenging his imprisonment in the same court, with appointed counsel.
Permission to Proceed Without Paying Filing Fees
The court addressed Bonilla's possible requests to proceed without paying filing fees, a status commonly called proceeding “in forma pauperis.” Under 28 U.S.C. § 1915(g), the court said Bonilla had previously been disqualified from that status unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if a request to proceed without paying fees were granted, the lawsuits would be barred under the rules discussed in 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 merits ruling on the underlying claims.
Ruling
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 those closed cases. The court additionally stated that the repetitive and frivolous nature of the filings did not require the judge to recuse herself, even though Bonilla named her as a defendant in one of the cases and, according to the opinion, gave no legitimate reason for recusal.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.