Bonilla v. California Appellate Court
- Phyllis Hamilton
- 4:20-cv-02993
- U.S. District Court · Northern District of California
- 2
Bonilla v. California Appellate Court: Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without filing-fee relief and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, his pending motions were terminated, and the cases were closed. The order also directed the clerk to return later documents without filing them.
What happened
In Bonilla v. California Appellate Court, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. He challenged his conviction and the handling of his petitions challenging court decisions.
The court said Bonilla had already been barred from proceeding without paying filing fees because of his prior cases. It also found that his allegations did not show an immediate danger when he filed the lawsuits and said the claims were barred for other legal reasons even if fee relief were granted.
The court dismissed all the cases with prejudice, ended the pending motions, and ordered the clerk to close the cases and return later filings without filing them. Judge Phyllis J. Hamilton issued the order.
The detailed version
- Bonilla v. California Appellate Court · No. 4:20-cv-02993
- Phyllis Hamilton
- June 11, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He also asked to proceed without prepaying filing fees. The complaints named various federal judges, state judges, municipalities, and state and county officials as defendants.
The opinion states that Bonilla presented similar claims in the cases and sought relief related to his underlying conviction or to the way state and federal courts handled his petitions challenging his conviction or custody. It also states that he had a pending federal petition in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Reasoning
The court stated that Bonilla had already been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g), which limits that relief for certain prisoners with qualifying prior cases. The court further found that the complaints did not show that Bonilla faced an imminent danger when he filed them. For that reason, he could not proceed without prepaying the filing fees.
The court added that, even if Bonilla had been allowed to proceed without prepaying fees, the lawsuits would be barred under several cited legal doctrines and decisions, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not analyze whether the defendants actually violated Bonilla's rights.
Ruling
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted after the cases were closed. 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.