Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:22-cv-05076
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Napa County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing-fee relief and his lawsuits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the named federal and state judges and state courts were defendants in those cases.
What happened
Bonilla v. Napa County Superior Court involved multiple lawsuits filed by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. He brought civil-rights claims against numerous federal and state judges and state courts, challenging his conviction and how other cases had been handled.
The court said Bonilla had previously been disqualified from proceeding without paying filing fees unless he showed that he faced an imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he were allowed to proceed without paying fees, the lawsuits would be barred under several cited legal rules and cases.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:22-cv-05076
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers these case numbers: 22-cv-4905-PJH, 22-cv-4971-PJH, 22-cv-4999-PJH, 22-cv-5010-PJH, 22-cv-5074-PJH, 22-cv-5076-PJH, 22-cv-5078-PJH, 22-cv-5120-PJH, 22-cv-5125-PJH, 22-cv-5127-PJH, 22-cv-5129-PJH, 22-cv-5130-PJH, and 22-cv-5131-PJH.
Bonilla presented nearly identical claims in the cases. He named dozens of federal and state judges and various state courts as defendants. The order says he sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. The order also notes that he had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status
The court addressed Bonilla's request, or possible request, to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified under that provision generally cannot proceed without paying the fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla's allegations did not show imminent danger at that time.
Other barriers identified by the court
The court further stated that, even if an application to proceed without paying the filing fee 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 order did not provide a separate merits determination of Bonilla's underlying claims.
Ruling and case status
The court dismissed the cases with prejudice. It also rejected the argument that the judge's impartiality could reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
The order was signed by United States District Judge Phyllis J. Hamilton on September 12, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.