Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:24-cv-00423
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Del Norte Superior Court, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding no imminent danger and multiple legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and required future documents submitted in those cases to be returned without filing.
What happened
In Bonilla v. Del Norte Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer. He named various federal and state judges and state courts as defendants and sought relief concerning his conviction and how other cases were handled.
Bonilla had been disqualified from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his allegations did not show such danger. The court also said that, even if he could proceed without paying fees, several legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that future documents submitted in those closed cases be returned without filing. Judge Phyllis J. Hamilton also declined to recuse herself, finding no reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:24-cv-00423
- Phyllis Hamilton
- Jan. 29, 2024
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers the case numbered 23-cv-6555-PJH and numerous related cases. The complaints were nearly identical. Bonilla named various federal and state judges and state courts as defendants and sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings. The court also noted his extensive history of filing similar cases.
Filing-fee determination
The court held that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he showed that 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. As a result, he could not proceed without paying the filing fees.
Other legal barriers
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the rules or doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not resolve the underlying challenges to Bonilla’s conviction or to the handling of his other cases.
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.
The order separately addressed recusal. Although Bonilla named Judge Hamilton as a defendant in one of the cases, the court found no legitimate reason to question her impartiality and declined to recuse herself.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.