Bonilla v. Superior Court, County of Monterey
- Phyllis Hamilton
- 4:21-cv-01491
- U.S. District Court · Northern District of California
- 2
Bonilla v. State of California: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple self-represented civil-rights cases were dismissed with prejudice; the named government defendants were affected by the closure of those cases.
What happened
In Bonilla v. State of California, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple civil-rights complaints against federal judges, state judges, counties, and federal agencies. He challenged his conviction and how state and federal courts handled his petitions and other cases.
The court found that Bonilla was barred from proceeding without paying filing fees because his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if he could proceed without paying, the lawsuits would be barred under several legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Superior Court, County of Monterey · No. 4:21-cv-01491
- Phyllis Hamilton
- Mar. 9, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government actors. The complaints named various federal judges, state judges, counties, and federal agencies as defendants. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction and the handling of his self-filed petitions and other cases.
The opinion also noted that Bonilla had a pending federal petition concerning his conviction in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court held that Bonilla was disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), 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.
Other Grounds for Dismissal
The court further stated that, even if Bonilla’s request to proceed without paying filing fees were granted, the lawsuits would be barred under the rules or doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those grounds.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on March 9, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.