Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:22-cv-05132
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Humboldt County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and procedural barriers.
Steven Wayne Bonilla and the state courts, judges, and state and federal officials he sued; the order closed the multiple cases and barred refiling those cases.
What happened
In Bonilla v. Humboldt County Superior Court, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases under federal law. He sued several state courts, state judges, and state and federal officials over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees unless he showed an immediate risk of serious physical injury. The complaints did not show that risk. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and court-related conduct.
The court dismissed the cases with prejudice, ended all pending motions, closed the cases, and ordered that future documents be returned without filing. Judge Phyllis J. Hamilton issued the order on September 19, 2022.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:22-cv-05132
- Phyllis Hamilton
- Sept. 19, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The cases involved nearly identical claims. Bonilla named several state courts, state judges, and state and federal officials as defendants. The complaints sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same district, represented by appointed counsel, and was also represented by counsel in state-court proceedings concerning his custody.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That restriction has an exception when a prisoner shows that he faced an imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger at the relevant time.
Other Bars Identified by the Court
The court further stated that, even if Bonilla’s applications to proceed without paying 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 conduct a merits determination of Bonilla’s underlying civil-rights allegations.
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. Judge Phyllis J. Hamilton signed the order.
Classification Basis
This is a procedural order because the court disposed of the cases based on the filing-fee restriction and other threshold or procedural barriers rather than deciding the underlying civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.