Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:22-cv-05073
- 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 filing fees and the lawsuits were barred.
Steven Wayne Bonilla's nine listed civil-rights cases were dismissed with prejudice; the order also directed the clerk to close those cases and return later submissions without filing them.
What happened
In Bonilla v. County of Alameda, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against counties and state and federal officials. He sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. His complaints did not show that danger. The court also said that, even if he were allowed to proceed without paying fees, the lawsuits were barred by other legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:22-cv-05073
- Phyllis Hamilton
- Sept. 12, 2022
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed nine civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named several counties and state and federal officials. The court said the complaints presented nearly identical claims seeking relief concerning Bonilla's underlying conviction or the way his other state and federal cases had been handled.
The court 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. The opinion did not decide the merits of the conviction-related or case-handling claims.
Inability to Proceed Without Paying Filing Fees
Bonilla sought, or potentially sought, permission to proceed without paying the filing fees. The court stated that he had been disqualified under 28 U.S.C. § 1915(g), a rule limiting fee waivers for prisoners with certain prior filings, unless he was under imminent danger of serious physical injury when he filed the complaints.
The court found that the allegations did not show imminent danger at the time of filing. It therefore held that Bonilla could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if Bonilla's request to proceed without paying fees were granted, the lawsuits would be barred under the legal rules and decisions identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each of those grounds.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Classification
This is a procedural order. The court disposed of the cases based on Bonilla's inability to proceed without paying filing fees and other threshold legal bars, without deciding whether his underlying claims were legally correct.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.