Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:21-cv-10025
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Marin County, Judge Hamilton dismissed multiple civil-rights cases with prejudice because the plaintiff could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 lawsuits were dismissed with prejudice. The defendants were the counties and other entities or individuals named in those complaints, but the opinion’s caption and text do not identify all of them.
What happened
In Bonilla v. Marin County, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. The lawsuits sought relief concerning his conviction or how state and federal courts handled his other cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed an immediate serious physical danger. The complaints did not show that danger. The court also said the lawsuits would be barred by several legal rules even if he qualified to proceed without paying.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:21-cv-10025
- Phyllis Hamilton
- Jan. 7, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. 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 identifies Marin County and other defendants.
The court stated that the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases. The opinion also noted that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee restriction
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. As a result, Bonilla could not proceed without paying the filing fee.
Other barriers 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 separately analyze each of those authorities in the quoted order.
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.
The opinion additionally addressed recusal. It concluded that the cases were not ones in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. One complaint named the judge as a defendant, but the court stated that it contained no specific allegations against her.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.