Bonilla v. Superior Court, County of Santa Cruz
- Phyllis Hamilton
- 4:21-cv-01523
- U.S. District Court · Northern District of California
- 2
In Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying separate legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and the defendants named in those complaints were no longer required to litigate them in those cases. The clerk was directed to close the cases and return later submissions without filing 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 known as Section 1983. The complaints named various federal judges, state judges, counties, and federal agencies and raised claims about his conviction and how courts handled his other cases.
The court found that Bonilla did not show he was in immediate danger of serious physical injury when he filed the complaints. Because he had previously been barred from proceeding without paying filing fees under the applicable law, he could not proceed that way. The court also said that, even if it granted that status, the lawsuits would be barred by other legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to end all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Superior Court, County of Santa Cruz · No. 4:21-cv-01523
- Phyllis Hamilton
- Mar. 9, 2021
Background
Steven Wayne Bonilla, identified in the order as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute used to bring certain civil-rights claims. The complaints named various federal judges, state judges, counties, and federal agencies. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction and the handling of his pro se habeas petitions and other cases. The order also noted that Bonilla had a pending federal habeas petition in the court with appointed counsel and was represented by counsel in state habeas proceedings.
The order lists multiple related case numbers, including 21-cv-01345-PJH, 21-cv-01346-PJH, 21-cv-01452-PJH, 21-cv-01489-PJH, 21-cv-01490-PJH, 21-cv-01491-PJH, 21-cv-01520-PJH, 21-cv-01521-PJH, 21-cv-01522-PJH, 21-cv-01523-PJH, 21-cv-01576-PJH, 21-cv-01577-PJH, 21-cv-01578-PJH, 21-cv-01579-PJH, 21-cv-01580-PJH, and 21-cv-01581-PJH.
Reasoning
The court addressed Bonilla’s requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore held that he could not proceed without paying the filing fees.
The court added that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not explain separately how each cited rule applied to each complaint.
Disposition
The court dismissed the cases with prejudice. It also ordered the clerk to terminate all pending motions and close the cases. The clerk was directed to return, without filing, any further documents Bonilla submitted in those closed cases. The order was signed by Judge Phyllis J. Hamilton on March 9, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.