Bonilla v. Superior Court, County of Mendocino
- Phyllis Hamilton
- 4:20-cv-06366
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after ruling Bonilla could not proceed without fee-free status and faced several legal bars.
Steven Wayne Bonilla and the multiple civil-rights cases covered by the order; the order also directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Bonilla v. Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights cases against various state courts. He sought relief related to his conviction and the way state and federal courts handled his petitions and other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from fee-free filing and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if he were allowed to proceed without fees, several legal doctrines would bar the lawsuits.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of Mendocino · No. 4:20-cv-06366
- 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 order covers the case numbers listed in the caption, including 20-cv-06002-PJH, 20-cv-06003-PJH, 20-cv-06114-PJH, and the other related cases. Bonilla named various state courts as defendants. The court said his requested relief concerned his underlying conviction or the handling of his various petitions and other cases by state and federal courts.
The order also noted that Bonilla had a pending federal petition challenging his custody in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee ruling
To proceed without paying the filing fee, Bonilla needed to qualify for that status under the federal prisoner-filing statute. The court ruled that he had already been disqualified from proceeding without fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fees.
Other legal bars and disposition
The court further stated that, even if an application to proceed without fees 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 order did not provide additional analysis of those cited authorities. The court dismissed the cases with prejudice.
The court also rejected the idea that its judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It stated that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and legal bars 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.