Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:23-cv-01580
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk to return future filings in them without filing.
What happened
In Bonilla v. Monterey County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer. He sued various federal and state judges and county officials and sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without filing fees under a rule limiting such filings by prisoners, unless they face imminent danger of serious physical injury. The complaints did not show that kind of danger. The court also said the lawsuits would be barred even if permission to proceed without fees were granted, citing rules and doctrines concerning challenges to convictions, ongoing state proceedings, and interference with other courts' cases.
The cases were dismissed with prejudice. Judge Phyllis J. Hamilton also ordered the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in them.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:23-cv-01580
- Phyllis Hamilton
- Apr. 14, 2023
Background
Steven Wayne Bonilla, identified in the opinion as a state prisoner and a condemned prisoner, filed multiple pro se complaints under 42 U.S.C. § 1983. “Pro se” means that he filed without a lawyer. The complaints presented nearly identical claims against various federal and state judges and county officials. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody.
Court’s analysis
The court addressed Bonilla’s possible requests to proceed in forma pauperis, meaning without paying the filing fee. Under 28 U.S.C. § 1915(g), the court said Bonilla had already been disqualified from proceeding without the fee unless he showed that 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.
The court added that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the authorities it cited: Heck v. Humphrey, concerning civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, concerning federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
The court separately addressed impartiality. It said the repetitive and frivolous nature of the filings did not create a situation in which the assigned judge’s impartiality could reasonably be questioned. A footnote states that Bonilla named the judge as a defendant in one of the cases but presented no legitimate basis for recusal.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It further ordered the clerk to return, without filing, any additional documents Bonilla submitted in those closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.