Bonilla v. Superior Court of San Francisco County, The
- Phyllis Hamilton
- 4:20-cv-06339
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla's multiple self-represented civil-rights cases, including the pending motions and any further filings in those closed cases.
What happened
In Bonilla v. Superior Court of San Francisco County, The, Steven Wayne Bonilla, a state prisoner, filed multiple self-represented civil-rights cases against various state courts. He sought relief related to his conviction and to the handling of his habeas petitions and 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 that, even if he could proceed without paying, the lawsuits would be barred by other legal rules.
The court dismissed all the cases with prejudice, terminated the pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of San Francisco County, The · No. 4:20-cv-06339
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, identified by the court as a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The complaints named various state courts as defendants. The opinion says Bonilla sought relief concerning his underlying conviction and the handling of his self-represented habeas petitions and other cases by state and federal courts. The opinion also notes that he had a pending federal habeas petition in the same district with appointed counsel and was represented by counsel in state habeas proceedings.
Reasoning
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed his complaint. The court found that the allegations did not show such imminent danger. Accordingly, Bonilla could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion also addressed the repetitive and frivolous nature of the filings and stated that this was not a situation in which the judge's impartiality could reasonably be questioned.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. 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.