Bonilla v. Superior Court, County of Santa Clara
- Phyllis Hamilton
- 4:21-cv-01521
- U.S. District Court · Northern District of California
- 2
Judge Hamilton dismissed Bonilla v. State of California’s multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named federal judges, state judges, counties, and federal agencies were defendants.
What happened
In Bonilla v. State of California, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights lawsuits against federal judges, state judges, counties, and federal agencies. His claims concerned his conviction and how state and federal courts handled his other cases and petitions.
The court found that Bonilla’s complaints did not show he faced imminent danger of serious physical injury when he filed them. Because of earlier rulings, he could not proceed without paying the filing fee unless that exception applied. The court also said the lawsuits would be barred by several other legal rules even if his applications had been granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was instructed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of Santa Clara · No. 4:21-cv-01521
- Phyllis Hamilton
- Mar. 9, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against government actors. The order lists these case numbers: 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.
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 other petitions and cases in state and federal court. The order also noted that he had a pending federal petition with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying the Filing Fee
Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee based on earlier rulings. Section 1915(g) permits an exception when a prisoner shows that he was in imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the relevant time. It therefore held that Bonilla could not proceed without paying the filing fee. The order further stated that, even if an application to proceed without paying the fee 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.
Disposition
The court dismissed the cases with prejudice. The order also directed 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.