Bonilla v. Superior Court of Del Norte County, The
- Phyllis Hamilton
- 4:20-cv-06338
- U.S. District Court · Northern District of California
- 2
Bonilla v. Superior Court of Del Norte County, The: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his claims faced legal bars.
Steven Wayne Bonilla, the multiple civil-rights cases he filed, and the various state-court defendants named in those complaints.
What happened
In Bonilla v. Superior Court of Del Norte County, The, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases challenging his conviction and how courts handled his other cases.
The court found that Bonilla could not receive a fee waiver because he had not shown an immediate serious physical danger when he filed. The court also said the lawsuits would be barred for other legal reasons even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court of Del Norte County, The · No. 4:20-cv-06338
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers case numbers 20-cv-06002-PJH, 20-cv-06003-PJH, 20-cv-06114-PJH, 20-cv-06293-PJH, 20-cv-06294-PJH, 20-cv-06295-PJH, 20-cv-06296-PJH, 20-cv-06329-PJH, 20-cv-06330-PJH, 20-cv-06338-PJH, 20-cv-06339-PJH, 20-cv-06341-PJH, 20-cv-06342-PJH, 20-cv-06366-PJH, 20-cv-06367-PJH, 20-cv-06369-PJH, 20-cv-06370-PJH, 20-cv-06394-PJH, 20-cv-06395-PJH, 20-cv-06396-PJH, 20-cv-06397-PJH, and 20-cv-06461-PJH. The complaints named various state courts as defendants and sought relief concerning Bonilla's underlying conviction and the handling of his other state and federal court cases.
The order states that Bonilla had a pending federal petition challenging his custody, with appointed counsel, and was also represented by counsel in state-court proceedings.
Fee-waiver restriction
Bonilla was barred under 28 U.S.C. § 1915(g) from proceeding without paying the filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the fees.
Other legal bars
The court further stated that, even if Bonilla's request to proceed without paying fees had been granted, the lawsuits would be barred under the legal principles 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 principles.
Ruling
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the judge's impartiality. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.