Bonilla v. Superior Court, County of Santa Cruz
- Phyllis Hamilton
- 4:20-cv-06003
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Superior Court, County of Santa Cruz, Judge Hamilton dismissed multiple civil-rights cases with prejudice because no imminent danger was shown and legal bars applied.
Steven Wayne Bonilla, who filed the multiple cases without a lawyer, was affected by the denial of permission to proceed without paying filing fees and by the dismissal of the cases with prejudice. The opinion states that various state courts were named as defendants.
What happened
Bonilla v. Superior Court, County of Santa Cruz involved multiple civil-rights complaints filed without a lawyer by Steven Wayne Bonilla, a condemned state prisoner. The complaints named various state courts and sought relief related to his conviction and the handling of his other cases and petitions.
The court ruled 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 stated that, even if he had been allowed to proceed without those fees, the lawsuits would be barred under several legal rules. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also ruled that the repetitive and frivolous filings did not provide a basis to question her impartiality. The clerk was directed to terminate pending motions, close the cases, and return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of Santa Cruz · No. 4:20-cv-06003
- Phyllis Hamilton
- Sept. 21, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion identifies the cases by numerous case numbers. Bonilla was also pursuing a federal petition concerning his conviction with appointed counsel and was represented by counsel in state-court proceedings.
The complaints named various state courts as defendants. They sought relief concerning Bonilla's underlying conviction and the handling of his petitions and other cases in state and federal court.
Filing-fee status
Bonilla sought, or attempted to seek, permission to proceed without paying the filing fees, a status commonly called proceeding "in forma pauperis." The court stated that 28 U.S.C. § 1915(g) disqualified him from that status unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
Ruling
The court further stated that, even if Bonilla had been allowed to proceed without paying the filing fees, 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 did not provide a separate claim-by-claim analysis of those rules. It ordered that the cases be dismissed with prejudice.
The court also addressed impartiality. It stated that these 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 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.