Bonilla v. Superior Court of Contra Costa County
- Phyllis Hamilton
- 4:20-cv-06342
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice, finding no imminent danger and citing other legal barriers.
Steven Wayne Bonilla, whose multiple civil-rights cases were dismissed with prejudice and closed; the defendants in those cases were also affected by the dismissals.
What happened
In Bonilla v. Superior Court of Contra Costa County, Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer under a federal law allowing claims against state officials. He challenged his conviction and the handling of other cases by state and federal courts.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from proceeding without fees unless he faced imminent danger of serious physical injury. The complaints did not show such danger. The court also said the lawsuits would be barred for additional legal reasons even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in those cases without filing them.
The detailed version
- Bonilla v. Superior Court of Contra Costa County · No. 4:20-cv-06342
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various state courts as defendants and sought relief concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court. The opinion also notes that Bonilla had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
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 showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Additional grounds for dismissal
The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis explaining which cited doctrine applied to which complaint.
Ruling
The court dismissed the cases with prejudice. It also stated that the cases were not ones in which the judge’s impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. 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.
Classification basis
This is a procedural order because the court dismissed the cases based on the filing-fee restriction and other threshold legal barriers rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.