Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:23-cv-05457
- U.S. District Court · Northern District of California
- 2
Bonilla v. Monterey County Superior Court was dismissed with prejudice after Judge Hamilton found no imminent danger and identified procedural bars.
Steven Wayne Bonilla and the multiple related civil-rights cases he filed against various state courts and judges; the order also directed the clerk to close those cases and reject further submissions in them.
What happened
Bonilla v. Monterey County Superior Court involved multiple complaints filed without a lawyer by Steven Wayne Bonilla, a state prisoner. The complaints asserted civil-rights claims against various state courts and judges and concerned his conviction or the handling of other cases.
The court ruled that Bonilla could not proceed without paying the required filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without those fees, the lawsuits were barred under several legal rules, and it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also denied Bonilla’s request for her recusal in one case. The clerk was directed to terminate pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:23-cv-05457
- 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 defendants included various state courts and judges. The complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases.
The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without prepaying filing fees, under 28 U.S.C. § 1915(g). That restriction contains an exception when a prisoner shows that he was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such imminent danger. Accordingly, Bonilla could not proceed in forma pauperis in these cases.
Other grounds for dismissal
The court further stated that, even if an application to proceed in forma pauperis were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze which cited bar applied to which complaint. The court therefore dismissed the cases with prejudice.
Because the dismissal rested on filing-fee eligibility and legal bars rather than a decision resolving the underlying civil-rights claims, this is a procedural order.
Recusal and case closure
A footnote stated that Bonilla named Judge Hamilton as a defendant in one case and sought her recusal. Judge Hamilton denied the recusal request, finding Bonilla’s arguments meritless in light of his numerous similar filings over many years.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed 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.