Bonilla v. Hamilton
- Phyllis Hamilton
- 4:23-cv-03593
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed the prisoner’s related civil-rights cases with prejudice because he could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The court also ended the pending motions, closed the cases, and directed the clerk not to file further documents Bonilla submitted in them.
What happened
In Bonilla v. Monterey County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against various federal and state judges. He sought relief concerning his conviction and how other state and federal cases had been handled.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an immediate risk of serious physical injury. The court found that his complaints did not show such a risk. It also said that, even if he could proceed without paying, the lawsuits would be barred by legal rules protecting criminal judgments, limiting interference with ongoing proceedings, or restricting challenges to how other courts acted.
Judge Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future documents from Bonilla without filing them.
The detailed version
- Bonilla v. Hamilton · No. 4:23-cv-03593
- Phyllis Hamilton
- July 28, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law that permits certain claims against state officials for violating federal rights. He represented himself in these cases. The complaints were nearly identical and named various federal and state judges as defendants. Bonilla sought relief relating to his underlying conviction or to the handling of his other cases.
The court noted that Bonilla had a pending federal petition challenging his custody in the same court, where he had appointed counsel, and that he was also represented by counsel in state court proceedings.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That restriction applies unless a prisoner shows that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that Bonilla’s allegations did not show such danger at the time of filing. The court therefore ruled that he could not proceed without paying the filing fee.
Other grounds identified by the court
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under one or more of the legal rules identified in the opinion: Heck v. Humphrey, which can restrict civil claims that would undermine a criminal judgment; Younger v. Harris, which limits federal interference with certain ongoing proceedings; and decisions concerning challenges to federal court proceedings. The opinion did not analyze each complaint separately in the text provided.
The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. It cited the principle that, absent legitimate reasons for disqualification, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases with prejudice. The court directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.