Bonilla v. County of Napa
- Phyllis Hamilton
- 4:22-cv-04904
- U.S. District Court · Northern District of California
- 2
In Bonilla v. County of Alameda, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla and the defendants named in the nine consolidated-in-one-order cases, including counties and state and federal officials.
What happened
In Bonilla v. County of Alameda et. al., Steven Wayne Bonilla, a state prisoner representing himself, filed nine nearly identical civil-rights lawsuits against counties and state and federal officials. He challenged his conviction or the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate serious physical danger when he filed. His complaints did not make that showing. The court also said the lawsuits would be barred for other legal reasons even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and ordered that later documents be returned without being filed.
The detailed version
- Bonilla v. County of Napa · No. 4:22-cv-04904
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named several counties and state and federal officials. They presented nearly identical claims seeking relief related to Bonilla’s underlying conviction or the handling of his other state and federal cases.
The order states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state proceedings concerning the same general subject matter.
Court’s analysis
The court addressed Bonilla’s requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying merits of Bonilla’s claims.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed 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.