Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:23-cv-05854
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice. The order also affected the named state courts and judges as defendants and directed the clerk to close the related cases and return future filings without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed many nearly identical civil-rights lawsuits without a lawyer against state courts and judges. He challenged his conviction and how his other cases had been handled.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from using the fee-waiver process and had not shown imminent danger of serious physical injury. The court also said that, even if he could proceed without paying fees, the lawsuits would be barred for the reasons identified in several cited decisions. The cases were dismissed with prejudice, all pending motions were terminated, and the clerk was directed to close the cases and return later filings without filing them.
Judge Phyllis J. Hamilton also denied Bonilla’s request for her recusal, finding his arguments meritless in light of his numerous similar filings. The court issued the order on November 27, 2023.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:23-cv-05854
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included various state courts and judges. The complaints sought relief concerning Bonilla’s underlying conviction and the way state and federal courts had handled his other cases.
The order covered the following related case numbers: 23-cv-5457-PJH, 23-cv-5515-PJH, 23-cv-5658-PJH, 23-cv-5659-PJH, 23-cv-5853-PJH, 23-cv-5854-PJH, 23-cv-5855-PJH, 23-cv-5856-PJH, 23-cv-5899-PJH, 23-cv-5900-PJH, 23-cv-5901-PJH, 23-cv-5965-PJH, 23-cv-5966-PJH, 23-cv-5967-PJH, 23-cv-5969-PJH, 23-cv-6056-PJH, 23-cv-6057-PJH, and 23-cv-6058-PJH.
Fee-waiver status and dismissal grounds
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the filing fee, unless he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under the principles 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 provide a separate claim-by-claim analysis of those authorities. The court accordingly dismissed the cases with prejudice.
Recusal request and case administration
Bonilla named Judge Hamilton as a defendant in one of the cases, No. 23-cv-5965-PJH, and requested her recusal. Judge Hamilton denied the request, stating that Bonilla’s arguments were meritless in light of his numerous similar filings over many years. The court also stated that the repetitive and frivolous nature of the filings did not provide a basis for questioning the judge’s impartiality.
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.
Disposition
The court dismissed all of the related cases with prejudice and denied the recusal request. The order was signed by Phyllis J. Hamilton, United States District Judge, on November 27, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.