Bonilla v. Superior Court, County of Santa Clara
- Phyllis Hamilton
- 4:20-cv-06330
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple self-represented civil-rights cases were dismissed with prejudice, and the clerk was directed to close them and return future submissions without filing them.
What happened
In Bonilla v. Superior Court, County of Santa Clara, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases under a federal law allowing claims against state actors. His complaints concerned his conviction and the handling of his other cases and petitions by state and federal courts.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate danger of serious physical injury. The complaints did not make that showing. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and federal courts’ handling of cases.
Judge Phyllis J. 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 Santa Clara · No. 4:20-cv-06330
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The opinion says he named various state courts as defendants and sought relief concerning his underlying conviction and the handling of his other self-represented petitions and cases by state and federal courts. The opinion also notes that he 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 filing fees under 28 U.S.C. § 1915(g). That rule permits a disqualified prisoner to proceed without paying only if he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several authorities. These included rules limiting civil-rights challenges that would undermine a conviction, rules requiring federal courts to refrain from interfering with certain ongoing state proceedings, and rules concerning challenges to the actions of federal courts. The opinion cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Ruling and Case Closure
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings, citing the general duty of a judge to handle assigned cases absent legitimate grounds for recusal. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the 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.