Bonilla v. Monahan
- Phyllis Hamilton
- 4:23-cv-05901
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla ineligible for fee-free filing and barred claims.
Steven Wayne Bonilla and the defendants in the multiple listed civil-rights cases, including state courts and judges.
What happened
In Bonilla v. Monterey County Superior Court et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state courts and judges. He challenged his conviction and how his other cases had been handled.
The court found that Bonilla was barred from filing without paying the filing fee unless he faced imminent danger of serious physical injury, and his complaints did not show such danger. The court also said the lawsuits would be barred by several legal rules even if he could proceed without paying the fee, so it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also denied Bonilla’s request that she step aside from one case, directed the clerk to end all pending motions and close the cases, and ordered that later documents in those closed cases be returned without filing.
The detailed version
- Bonilla v. Monahan · No. 4:23-cv-05901
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases named various state courts and judges as defendants. The complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his other cases.
The opinion also states that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee ruling
The court held that Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), 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. The opinion therefore states that Bonilla could not proceed without paying the filing fee.
Other legal barriers and disposition
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several legal doctrines and decisions, including rules concerning challenges to criminal convictions, ongoing state proceedings, restrictions on certain challenges to federal-court actions, and limits on lawsuits against federal bankruptcy courts. The court accordingly dismissed the cases with prejudice.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Recusal request
A footnote states that Bonilla named Judge Hamilton as a defendant in one of the cases, Case No. 23-cv-5965-PJH, and requested her recusal. Judge Hamilton denied that request, stating that Bonilla’s arguments were meritless in light of his numerous similar filings over many years.
Classification basis
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and legal barriers without deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.