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N.D. Cal.Procedural orderFiled Aug. 24, 2022

Bonilla

Judge
Phyllis Hamilton
Docket
4:22-cv-04736
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. County of Santa Cruz, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice after finding no imminent danger and additional legal bars.

Who this affects

Steven Wayne Bonilla, whose multiple complaints were dismissed with prejudice and who could not proceed without paying the filing fee; the counties and state officials he sued; and the clerk handling the closed cases.

What happened

Steven Wayne Bonilla filed multiple nearly identical civil-rights cases against several counties and state officials, seeking relief related to his underlying conviction. The court noted that he was a condemned prisoner and that he had counsel in related federal and state proceedings.

The court ruled that Bonilla could not proceed without paying the filing fee because he had been disqualified from that status and had not shown that he faced imminent danger of serious physical injury when he filed. The court also stated that the lawsuits would be barred by other legal rules 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 ordered the clerk to return any further documents Bonilla submits in the closed cases without filing them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla · No. 4:22-cv-04736
Judge
Phyllis Hamilton
Date
Aug. 24, 2022

Background

Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints asserted nearly identical claims against several counties and state officials and sought relief concerning his underlying conviction. The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings.

Proceeding Without Paying the Filing Fee

The court explained that Bonilla had been disqualified from proceeding without paying the filing fee 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. Bonilla therefore could not proceed without paying the filing fee in these cases.

Other Bars and Disposition

The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under rules and precedents including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not specify which cited bar applies to which individual complaint. The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. It ordered the clerk to return, without filing, any further documents Bonilla submits in the closed cases. Judge Phyllis J. Hamilton signed the order.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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