Bonilla v. Solga
- Phyllis Hamilton
- 4:23-cv-06057
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed the civil-rights cases with prejudice because Bonilla did not qualify for fee-free filing and the suits faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases, the named state-court and judicial defendants, and any further documents Bonilla submits in those closed cases.
What happened
In Bonilla v. Monterey County Superior Court, Steven Wayne Bonilla filed multiple civil-rights cases without a lawyer against various state courts and judges. He challenged his conviction and the way other state and federal cases had been handled.
The court said Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he had qualified for fee-free filing, the lawsuits would be barred by several legal rules and prior decisions.
The court dismissed the cases with prejudice, denied Bonilla’s request for the judge’s recusal, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Solga · No. 4:23-cv-06057
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases named various state courts and judges as defendants. Bonilla’s complaints presented nearly identical claims and sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his detention in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings.
Filing-fee ruling and dismissal
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the required 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 authorities it cited, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court dismissed the cases with prejudice. The opinion does not describe a merits determination about whether Bonilla’s underlying conviction or other claims were legally valid.
Recusal request and case closure
The court addressed Bonilla’s request that the judge recuse herself. A footnote states that Bonilla named the judge as a defendant in one case, Case No. 23-cv-5965-PJH, and sought recusal. The court denied that request, stating that the arguments were meritless in light of Bonilla’s numerous similar filings over many years.
The court ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.