Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:22-cv-05134
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Humboldt County Superior Court, Judge Hamilton dismissed multiple civil-rights lawsuits with prejudice because filing-fee rules and other legal barriers applied.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, and he could not proceed in those cases without paying the filing fee or submit further documents for filing in them.
What happened
Bonilla v. Humboldt County Superior Court involved multiple nearly identical civil-rights lawsuits filed without lawyers by Steven Wayne Bonilla, a state prisoner. He sued several state courts, state judges, and state and federal officials, seeking relief related to his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the complaints did not make that showing. It also said that, even if permission to proceed without paying had been granted, the lawsuits would be barred under several legal rules and prior decisions cited in the order.
The court dismissed the cases with prejudice, meaning the dismissals were final as to these cases. It ordered the clerk to terminate pending motions, close the cases, and return any further documents without filing them. Judge Phyllis J. Hamilton issued the order on September 19, 2022.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:22-cv-05134
- Phyllis Hamilton
- Sept. 19, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included several state courts, state judges, and state and federal officials. The complaints sought relief concerning Bonilla’s underlying conviction or the way other cases had been handled by state and federal courts.
The order also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody.
Filing-fee issue
The court addressed Bonilla’s possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), the court said he had been disqualified from proceeding without prepaying the fee unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger at the relevant time. The order therefore concluded that Bonilla could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if a request to proceed without paying the fee had been 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 cited those authorities but did not separately explain how each one applied to each lawsuit. The court did not decide the underlying civil-rights claims.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and other threshold legal barriers without reaching the merits of Bonilla’s claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.