Bonilla v. Brady
- Phyllis Hamilton
- 4:23-cv-06058
- 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 because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also denied his request for Judge Hamilton to step aside and directed the clerk to close the cases and return later filings without filing them.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various state courts and judges. He sought relief related to his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he qualified to proceed without paying, the lawsuits were barred, and it dismissed the cases with prejudice. The clerk was ordered to close the cases and return later filings without filing them.
Judge Phyllis J. Hamilton also denied Bonilla’s request that she step aside from one case, finding his arguments meritless in light of his repeated similar filings.
The detailed version
- Bonilla v. Brady · No. 4:23-cv-06058
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, identified by the court as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a law that permits certain civil-rights claims against state actors. He represented himself in these cases. The complaints were nearly identical and named various state courts and judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The opinion also states that Bonilla had a pending federal petition concerning his imprisonment in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee ruling
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That restriction has an exception when a prisoner was in imminent danger of serious physical injury at the time of filing. The court found that the allegations in these complaints did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Reasons for dismissal
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court did not provide additional analysis of each rule in this order. It dismissed the cases with prejudice.
Recusal request and case closure
Bonilla named Judge Hamilton as a defendant in one of the cases and asked her to step aside. In a footnote, the court denied that request, calling 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 ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Disposition
The court dismissed the multiple cases with prejudice and denied the request for Judge Hamilton’s recusal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.