Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:21-cv-10022
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Marin County, Judge Hamilton dismissed multiple cases with prejudice because filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla and the defendants in the listed cases; the order dismissed all of the listed cases with prejudice and closed them.
What happened
Bonilla v. Marin County involved multiple nearly identical civil-rights complaints filed without a lawyer by Steven Wayne Bonilla, a state prisoner. The complaints sought relief concerning his conviction or the handling of his other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that status and had not shown an immediate risk of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:21-cv-10022
- Phyllis Hamilton
- Jan. 7, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a statute that allows claims for violations of federal rights by state actors. The caption 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 complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The court noted that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in which he had appointed counsel. It also noted that he was represented by counsel in state-court proceedings.
Filing-fee status and legal bars
The court ruled that, to the extent Bonilla sought permission to proceed without prepaying the filing fee, 28 U.S.C. § 1915(g) barred that status because he had previously been disqualified from it. The exception applies when a prisoner shows that he faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further ruled that, even if Bonilla had been allowed to proceed without prepaying the filing fee, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, which can prevent civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; and the rules discussed in Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court.
Ruling and case status
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not create a reasonable question about the undersigned judge’s impartiality. A footnote explained that Bonilla named the judge as a defendant in one case, but alleged no specific facts against her.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered 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.