Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:22-cv-04218
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying legal barriers.
Steven Wayne Bonilla's eight related civil-rights cases were dismissed with prejudice, and he could not proceed without paying the filing fee because the court found no imminent danger.
What happened
Bonilla v. Alameda County Superior Court concerns multiple complaints filed by Steven Wayne Bonilla, a state prisoner representing himself. The complaints raised nearly identical civil-rights claims against a federal judge, state courts, and state and federal officials, seeking relief related to his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been barred from proceeding without fees unless he faced imminent danger of serious physical injury. The complaints did not show that he faced such danger. The court also said the lawsuits would be barred even if permission to proceed without fees were granted.
Judge Hamilton dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that further documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:22-cv-04218
- Phyllis Hamilton
- July 26, 2022
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983. The cases listed a federal judge, various state courts, and several state and federal officials as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.
The order addressed eight related case numbers: 22-cv-3671-PJH, 22-cv-3767-PJH, and 22-cv-4214-PJH through 22-cv-4218-PJH. The court also noted that Bonilla had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state proceedings concerning that petition.
Filing-fee ruling
Bonilla sought, or might have sought, permission to proceed without paying the filing fee. The court stated that he had previously been disqualified from that status under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time. It therefore ruled that Bonilla 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 were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying validity of Bonilla's conviction or the alleged handling of his other cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on July 26, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.