Bonilla v. Reynolds
- Phyllis Hamilton
- 4:23-cv-05855
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Monterey County Superior Court, Judge Hamilton dismissed multiple Section 1983 civil-rights cases with prejudice because Bonilla could not proceed without fees and claims were barred.
Steven Wayne Bonilla’s multiple Section 1983 cases were dismissed with prejudice. The defendants included various state courts and judges, and the clerk was directed to close the cases and return future filings without filing them.
What happened
In Steven Wayne Bonilla v. Monterey County Superior Court et al., Steven Wayne Bonilla filed multiple civil-rights cases under Section 1983 without a lawyer. He challenged his conviction and the handling of his other cases, naming various state courts and judges as defendants.
The court ruled that Bonilla was barred from proceeding without paying filing fees because his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if his fee applications were granted, citing several legal doctrines.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. It also denied Bonilla’s request that Judge Phyllis J. Hamilton recuse herself and directed the clerk to return future filings in these closed cases without filing them.
The detailed version
- Bonilla v. Reynolds · No. 4:23-cv-05855
- Phyllis Hamilton
- Nov. 27, 2023
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. He named various state courts and judges as defendants and sought relief concerning his underlying conviction or the handling of other cases by state and federal courts. The opinion also states that Bonilla is a condemned prisoner with a pending federal petition challenging his conviction and has a lawyer in state-court proceedings.
Filing-fee status
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees 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 show such danger. Bonilla therefore could not proceed without paying the required fees.
Other barriers to the lawsuits
The court further stated that, even if Bonilla’s applications to proceed without paying fees 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 did not provide separate claim-by-claim analyses of those barriers.
Rulings and case status
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. In one of the cases, Bonilla named Judge Hamilton as a defendant and sought her recusal, meaning her removal from the case because of alleged impartiality concerns. Judge Hamilton denied that request, finding the recusal arguments meritless in light of Bonilla’s numerous similar filings.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.