Bonilla v. Superior Court of Santa Cruz
- Phyllis Hamilton
- 4:20-cv-04791
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court of Santa Cruz, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and the lawsuits were barred.
Steven Wayne Bonilla's fifteen listed civil-rights cases were dismissed with prejudice and closed; the named federal and state judges, municipalities, and other officials were no longer required to litigate those cases in the district court.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights cases against federal judges, state judges, municipalities, and other officials. He sought relief related to his conviction and the handling of his state and federal cases.
The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts. The court dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also stated that there was no basis to question her impartiality in the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of Santa Cruz · No. 4:20-cv-04791
- Phyllis Hamilton
- Aug. 20, 2020
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers these case numbers: 20-cv-02989-PJH, 20-cv-04791-PJH, 20-cv-04792-PJH, 20-cv-05250-PJH, 20-cv-05252-PJH, 20-cv-05591-PJH, 20-cv-05598-PJH, 20-cv-05600-PJH, 20-cv-05603-PJH, 20-cv-05652-PJH, 20-cv-05701-PJH, 20-cv-05774-PJH, 20-cv-05776-PJH, 20-cv-05827-PJH, and 20-cv-05847-PJH.
The complaints named various federal judges, state judges, municipalities, and other municipal and court officials. The court said that Bonilla presented similar claims in the cases and sought relief concerning his underlying conviction or the way state and federal courts handled his other petitions and cases. The order also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only when the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show such a danger. Bonilla therefore could not proceed without paying the filing fee.
Other Grounds for Dismissal
The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, which concerns civil claims that would undermine a conviction or sentence; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
Ruling and Case Status
The court dismissed the cases with prejudice. It also stated that the cases were not ones in which the presiding judge's impartiality could reasonably be questioned. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
Judge Phyllis J. Hamilton signed the order on August 20, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.