Bonilla v. San Benito Superior Court
- Phyllis Hamilton
- 4:22-cv-01028
- U.S. District Court · Northern District of California
- 2
In Bonilla v. San Benito Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and legal barriers to suit.
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 later submissions without filing them.
What happened
In Bonilla v. San Benito Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against counties, state courts, and clerk’s offices. He challenged his conviction and the handling of other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that status and had not shown an imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal doctrines even if his applications to proceed without paying were granted.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. San Benito Superior Court · No. 4:22-cv-01028
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified by the court as a state prisoner and a condemned prisoner, filed multiple similar civil-rights complaints under 42 U.S.C. § 1983. The caption of the opinion identifies the defendant as the Sonoma County Clerk’s Office, while the case information supplied for this summary identifies the matter as Bonilla v. San Benito Superior Court. The opinion lists multiple case numbers, including 22-cv-1014-PJH, 22-cv-1023-PJH, 22-cv-1025-PJH, 22-cv-1027-PJH, 22-cv-1028-PJH, 22-cv-1118-PJH, 22-cv-1511-PJH, 22-cv-1512-PJH, 22-cv-1513-PJH, 22-cv-1514-PJH, 22-cv-1515-PJH, 22-cv-1516-PJH, 22-cv-1529-PJH, 22-cv-1530-PJH, 22-cv-1545-PJH, and additional listed cases.
The court said the complaints presented nearly identical claims against several counties, state courts, and clerk’s offices. According to the court, Bonilla sought relief concerning his underlying conviction or the way other state and federal court cases had been handled. The opinion also noted that he had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
To the extent Bonilla sought to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the doctrines or rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate merits determination of Bonilla’s underlying claims.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.