Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:21-cv-10028
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Marin County, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice, and the clerk was directed to close them and return later submissions without filing.
What happened
Bonilla v. Marin County involved multiple nearly identical civil-rights complaints filed by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. The complaints sought relief related to his conviction or the handling of his other cases by state and federal courts.
The court said Bonilla was barred from proceeding without paying filing fees under a rule for prisoners with three or more qualifying prior cases, unless he faced imminent danger of serious physical injury. The allegations did not show such danger. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that further documents Bonilla submitted in those closed cases be returned without filing.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:21-cv-10028
- Phyllis Hamilton
- Jan. 7, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists these case numbers: 21-cv-010015-PJH, 21-cv-010016-PJH, 21-cv-010017-PJH, 21-cv-010018-PJH, 21-cv-010019-PJH, 21-cv-010020-PJH, 21-cv-010021-PJH, 21-cv-010022-PJH, 21-cv-010024-PJH, 21-cv-010025-PJH, 21-cv-010026-PJH, 21-cv-010028-PJH, 21-cv-010030-PJH, and 21-cv-010031-PJH. The caption names Marin County and other defendants.
The court stated that the complaints presented nearly identical claims. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The opinion also stated that he had a pending federal petition challenging his detention or conviction in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee status
The court addressed Bonilla’s possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner disqualified by qualifying prior cases 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 determined that Bonilla’s allegations did not show imminent danger at that time.
Other grounds identified by the court
The court further stated that, even if an application to proceed without paying the filing 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. The opinion did not provide a separate claim-by-claim analysis explaining which cited doctrine applied to which case.
The court also addressed impartiality. It stated that the repetitive and allegedly frivolous nature of the filings did not create a situation in which the judge’s impartiality could reasonably be questioned. A footnote states that Bonilla named the judge as a defendant in one case, case number 21-cv-010031-PJH, and that the complaint raised no specific allegations against the judge; the provided opinion text ends before the footnote is complete.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on January 7, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.