Bonilla v. Superior Court, County of Monterey
- Phyllis Hamilton
- 4:24-cv-02634
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, his pending motions were terminated, and the cases were closed. The clerk was directed to return future documents submitted in those closed cases without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights cases without a lawyer under a federal civil-rights law. He sued various state courts and federal judges, seeking relief related to his conviction and the handling of other cases.
The court found that Bonilla could not proceed without paying the filing fees because he was barred from that status and had not shown an immediate danger of serious physical injury when he filed. The court also said the lawsuits would be barred even if that status were granted. It dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in them without filing them.
Judge Phyllis J. Hamilton also rejected any claim that the repetitive filings required her to step aside. The order was entered on May 29, 2024.
The detailed version
- Bonilla v. Superior Court, County of Monterey · No. 4:24-cv-02634
- Phyllis Hamilton
- May 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints without a lawyer. The complaints asserted civil-rights claims under 42 U.S.C. § 1983. They named various state courts and federal judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The order addressed the following case numbers: 24-cv-2631-PJH, 24-cv-2632-PJH, 24-cv-2633-PJH, 24-cv-2634-PJH, 24-cv-2643-PJH, 24-cv-2644-PJH, 24-cv-2646-PJH, 24-cv-2647-PJH, 24-cv-2648-PJH, 24-cv-2649-PJH, 24-cv-2650-PJH, 24-cv-2651-PJH, 24-cv-2652-PJH, 24-cv-2712-PJH, 24-cv-2713-PJH, 24-cv-2714-PJH, 24-cv-2715-PJH, 24-cv-2741-PJH, 24-cv-2983-PJH, and 24-cv-3010-PJH.
Filing-fee status and legal bars
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only when the complaint shows that the prisoner faced an imminent danger of serious physical injury at the time of filing. The court found that these complaints did not show such danger, so Bonilla could not proceed under that status.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under legal rules and precedents identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order therefore dismissed the cases with prejudice. It also noted Bonilla’s extensive history of filing similar cases.
Recusal issue and disposition
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. Citing precedent stating that a judge generally has a duty to decide cases assigned to that judge absent legitimate grounds for recusal, the court declined to step aside.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases. The order disposed of the cases on filing-fee and legal-bar grounds rather than deciding the substance of Bonilla’s challenges to his conviction or the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.