Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:23-cv-05856
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed the cases with prejudice after finding no imminent-danger showing for IFP eligibility.
Steven Wayne Bonilla and the multiple civil-rights cases he filed against various state courts and judges; the order also directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Bonilla v. Monterey County Superior Court, 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 other state and federal cases were handled.
The court ruled that Bonilla could not proceed without paying the filing fees because his complaints did not show imminent danger of serious physical injury. The court also stated that the lawsuits would be barred under several legal doctrines even if his fee-waiver applications were granted, and dismissed the cases with prejudice. It terminated pending motions, closed the cases, and directed the clerk to return later filings without filing them.
Judge Phyllis J. Hamilton also denied Bonilla’s request for her recusal, finding his arguments meritless. The opinion states that Bonilla had named the judge as a defendant in one case and sought recusal because of the repetitive filings.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:23-cv-05856
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. 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 handling of his other cases by state and federal courts.
The opinion also states that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings. The listed cases include Nos. 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.
Filing-fee waiver and dismissal
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee, unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not make that showing, so he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying the filing fee 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 does not separately explain which doctrine applied to which complaint. The court dismissed the cases with prejudice, meaning the stated dismissal bars refiling those cases.
Recusal and case closure
The court rejected Bonilla’s request for recusal. A footnote states that he named the undersigned judge as a defendant in one case, No. 23-cv-5965-PJH, and sought recusal. The court found his arguments meritless in light of his numerous similar filings over many years.
The clerk was directed 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. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.