Bonilla v. Monterey County Superior Court, Its Judges and Clerks
- Phyllis Hamilton
- 4:23-cv-03304
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed the multiple civil-rights cases with prejudice after finding no imminent danger and citing additional legal bars.
Steven Wayne Bonilla, the plaintiff in the multiple cases, and the defendants named in those cases, including various federal and state judges. The order also directed the clerk’s handling of the closed cases and future filings.
What happened
In Bonilla v. Monterey County Superior Court, Its Judges and Clerks, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against various federal and state judges. He challenged his conviction and the handling of his other state and federal cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines.
Judge Phyllis Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases. The court also declined to recuse Judge Hamilton based on the repetitive filings, even though Bonilla named her as a defendant in one case.
The detailed version
- Bonilla v. Monterey County Superior Court, Its Judges and Clerks · No. 4:23-cv-03304
- Phyllis Hamilton
- July 28, 2023
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction and the way his other state and federal cases had been handled. The court described the claims as nearly identical across the cases.
Bonilla also had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings. The opinion lists multiple related case numbers, including 23-cv-3304-PJH, 23-cv-3446-PJH, 23-cv-3447-PJH, 23-cv-3589-PJH, 23-cv-3590-PJH, 23-cv-3591-PJH, 23-cv-3592-PJH, 23-cv-3593-PJH, 23-cv-3686-PJH, 23-cv-3687-PJH, 23-cv-3688-PJH, 23-cv-3690-PJH, 23-cv-3691-PJH, 23-cv-3693-PJH, 23-cv-3694-PJH, and 23-cv-3695-PJH.
Court’s reasoning
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not meet that condition, so he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not analyze the individual complaints separately or provide a separate merits determination for each claim.
Bonilla named Judge Hamilton as a defendant in one of the cases. Judge Hamilton concluded that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question her impartiality and did not require her recusal.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and 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.