Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:24-cv-01570
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Howard Lloyd, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and several legal barriers.
Steven Wayne Bonilla and the multiple cases covered by the order, all of which were dismissed with prejudice and closed.
What happened
In Bonilla v. Judge Howard Lloyd, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred by several legal doctrines even if his requests to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:24-cv-01570
- Phyllis Hamilton
- Mar. 27, 2024
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical and named various federal and state judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The order states that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings challenging his custody. The court also noted Bonilla’s extensive history of filing similar cases.
Proceeding Without Paying Filing Fees
The court addressed Bonilla’s possible requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has repeatedly filed qualifying cases generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified from proceeding without paying under that provision.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fees.
Other Legal Bars
The court further ruled that, even if an application to proceed without paying were granted, the lawsuits would be barred by the legal 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 provide a separate claim-by-claim analysis of those doctrines.
Recusal
The court also addressed the fact that Bonilla named the presiding judge as a defendant in three of the cases. It concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. The court cited the principle that, absent legitimate reasons for disqualification, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.