Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:23-cv-05658
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed the cases with prejudice, barred IFP status, and denied recusal.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. He could not proceed without paying the filing fee, and his recusal request was denied.
What happened
In Bonilla v. Monterey County Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against state courts and judges. He challenged his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he was disqualified from filing without fees and had not shown an immediate danger of serious physical injury. The court also said the lawsuits would be barred under several legal doctrines even if his fee-waiver request were granted, and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also denied Bonilla’s request for her recusal in one case. The clerk was ordered to terminate pending motions, close the cases, and return future filings in them without filing them.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:23-cv-05658
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple nearly identical lawsuits without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. The complaints named various state courts and judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled.
The order lists multiple case numbers, including 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. The order also notes that Bonilla had a pending federal petition with appointed counsel and was represented by counsel in state court proceedings.
Filing-fee status and dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), 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. Therefore, Bonilla could not proceed without paying the filing fee.
The court further stated that, even if a request to proceed without paying the 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 court accordingly dismissed the cases with prejudice. The opinion does not explain which particular doctrine applied to which individual case or claim.
Recusal and disposition
In a footnote, the court stated that Bonilla named Judge Hamilton as a defendant in one case, 23-cv-5965-PJH, 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 ordered to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on November 27, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.