Bonilla v. Superior Court, County of Napa
- Phyllis Hamilton
- 4:21-cv-01682
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Desautels, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and his lawsuits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return further documents submitted in those closed cases without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer against various federal judges, state judges, and superior courts. The complaints raised similar claims concerning his conviction and his other prisoner petitions.
The court said Bonilla had previously been disqualified from proceeding without paying the filing fee unless he showed that he faced an imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he were allowed to proceed without paying the fee, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Superior Court, County of Napa · No. 4:21-cv-01682
- Phyllis Hamilton
- Mar. 22, 2021
Background
Steven Wayne Bonilla, identified by the court as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against certain persons acting under state law. The complaints named various federal judges, state judges, and superior courts as defendants. The court said the complaints presented very similar claims concerning Bonilla’s underlying conviction or the handling of his other prisoner petitions.
The opinion also noted that Bonilla had a pending federal petition challenging his conviction in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings concerning another such petition.
Proceeding Without Paying the Filing Fee
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law permits a disqualified prisoner to proceed without paying the fee only if the prisoner was in imminent danger of serious physical injury when the complaint was filed.
The court found that Bonilla’s allegations did not show imminent danger at the time he filed these complaints. It therefore ruled that he could not proceed without paying the filing fee.
Other Grounds for Dismissal
The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would still be barred under the legal rules and decisions identified by the court, including 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.
The court also addressed impartiality because Bonilla named the undersigned judge as a defendant in one case. It found that the filings did not create a reasonable basis to question the judge’s impartiality, noting that the complaint contained no specific allegations against that judge.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed 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.