Bonilla v. County of Contra Costa
- Phyllis Hamilton
- 4:22-cv-04903
- U.S. District Court · Northern District of California
- 2
Bonilla v. County of Alameda: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla showed no imminent danger and procedural bars applied.
Steven Wayne Bonilla and the counties and state and federal officials named as defendants in the multiple cases.
What happened
In Bonilla v. County of Alameda, Steven Wayne Bonilla, a state prisoner, filed several nearly identical civil-rights lawsuits without a lawyer against counties and state and federal officials. He sought relief related to his conviction and the handling of his other state and federal cases.
The court said Bonilla was barred from proceeding without paying filing fees unless his complaints showed that he faced imminent danger of serious physical injury when he filed them. The court found that the complaints did not show such danger. It also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal rules involving challenges to convictions, ongoing proceedings, and court actions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. County of Contra Costa · No. 4:22-cv-04903
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named several counties and state and federal officials. The court said the complaints presented nearly identical claims and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal court cases.
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 custody proceedings.
Court’s Analysis
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that payment procedure may proceed only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla’s allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without paying filing 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 did not decide the underlying validity of Bonilla’s conviction or otherwise resolve the merits of the civil-rights claims.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed 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.