Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:23-cv-06430
- U.S. District Court · Northern District of California
- 2
In Bonilla v. O’Farrell et al., 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 § 1983 lawsuits were dismissed with prejudice, affecting his ability to continue those cases in the district court; the order also addressed the state courts and judges he named as defendants.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various state courts and judges. In Bonilla v. O’Farrell et al., he sought relief related to his conviction and the handling of other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying the filing fees because he had been disqualified from that status under the federal three-strikes rule. His complaints also did not show that he faced an immediate danger of serious physical injury when he filed them. The court further stated that the lawsuits would be barred even if his fee applications were granted.
The court dismissed the cases with prejudice, 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. Monterey County Superior Court · No. 4:23-cv-06430
- Phyllis Hamilton
- Dec. 21, 2023
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. Bonilla named various state courts and judges as defendants 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 custody in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings challenging his custody.
Court’s reasoning
The court addressed Bonilla’s possible requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner disqualified under the statute’s three-strikes rule may proceed without paying only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the fees.
The court additionally stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the decisions cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each cited basis.
Disposition
The court dismissed the cases with prejudice. It directed 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 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.