Bonilla v. County of San Benito
- Phyllis Hamilton
- 4:22-cv-04739
- U.S. District Court · Northern District of California
- 2
In Bonilla v. County of Santa Cruz, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The complaints named several counties and state officials as defendants.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer under a federal law allowing suits against officials. The complaints named several counties and state officials and sought relief concerning his underlying conviction.
The court said Bonilla could not use the filing-fee waiver because he had previously been disqualified from that status, and his complaints did not show that he faced imminent danger when he filed them. The court also said the lawsuits would be barred under several other legal rules even if the waiver were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents without filing them.
The detailed version
- Bonilla v. County of San Benito · No. 4:22-cv-04739
- Phyllis Hamilton
- Aug. 24, 2022
Background
Steven Wayne Bonilla, identified in the order as a state prisoner and condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain claims against government officials. The complaints were nearly identical, named several counties and state officials, and sought relief concerning Bonilla’s underlying conviction. The order also notes that Bonilla had a pending federal petition in the same court and state-court proceedings, both involving legal representation.
Filing-fee status
The court addressed Bonilla’s possible request to proceed without paying the filing fee. It stated that he had been disqualified from that status under 28 U.S.C. § 1915(g), unless he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger, so Bonilla could not proceed under the filing-fee waiver.
Other legal bars
The court further stated that, even if Bonilla’s request for the filing-fee waiver had been 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 order does not separately explain how each cited legal bar applies to each complaint.
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 submits 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.