Bonilla v. State of California
- Phyllis Hamilton
- 4:21-cv-01345
- U.S. District Court · Northern District of California
- 2
In Bonilla v. State of California, Judge Hamilton dismissed multiple cases with prejudice after finding Bonilla could not proceed without paying fees and his lawsuits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the order also directed the clerk to close the cases and reject future filings in them.
What happened
In Bonilla v. State of California, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights lawsuits under a federal law allowing claims against government officials. The complaints named various federal judges, state judges, counties, and federal agencies and challenged his conviction and the handling of his other cases.
The court said Bonilla was barred from filing without paying the court fee unless he showed that he faced an immediate risk of serious physical injury when he filed. The court found that his complaints did not show such a risk. It also said that, even if he were allowed to file without paying, the lawsuits would be barred by several legal doctrines concerning challenges to convictions, ongoing state proceedings, and suits against federal courts.
The court dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future submissions without filing them. Judge Phyllis J. Hamilton signed the order on March 9, 2021.
The detailed version
- Bonilla v. State of California · No. 4:21-cv-01345
- 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 permits certain civil-rights claims against government actors. The cases named various federal judges, state judges, counties, and federal agencies. The complaints presented similar claims seeking relief related to Bonilla's underlying conviction and the handling of his other self-filed petitions and cases.
The order also states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and that he is represented by counsel in state proceedings concerning his custody.
Court's analysis
The court addressed Bonilla's ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally may not proceed without paying unless he was in immediate danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified from proceeding without paying under that statute and that the allegations did not show imminent danger at the time of filing.
The court further stated that, even if Bonilla's requests to proceed without paying 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 separately explain which cited doctrine applies to which case or claim.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. Phyllis J. Hamilton entered the order on March 9, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.