Bonilla
- Phyllis Hamilton
- 4:22-cv-04741
- U.S. District Court · Northern District of California
- 2
Judge Hamilton dismissed Bonilla v. County of Santa Cruz’s multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the defendants in his multiple civil-rights cases, including the County of Santa Cruz and other named defendants; pending motions and later filings in the closed cases were also affected.
What happened
In Bonilla v. County of Santa Cruz, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. He sought relief concerning his underlying conviction and named counties and state officials as defendants.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from proceeding without fees, and his complaints did not show imminent danger of serious physical injury when filed. The court also said the lawsuits would be barred even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla · No. 4:22-cv-04741
- Phyllis Hamilton
- Aug. 24, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists ten related case numbers: 22-cv-4596-PJH, 22-cv-4624-PJH, and 22-cv-4736-PJH through 22-cv-4743-PJH. Bonilla presented nearly identical claims, named several counties and state officials as defendants, and sought relief concerning his underlying conviction. The opinion also notes that he had a pending federal petition challenging his detention or conviction with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee ruling
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner previously barred from proceeding without fees may do so only by showing that he was in imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore concluded that he could not proceed without paying the filing fees.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying fees 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 does not provide a separate claim-by-claim explanation of how each cited doctrine applied.
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 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.