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N.D. Cal.Procedural orderFiled Sept. 19, 2022

v. Bonilla

Judge
Phyllis Hamilton
Docket
4:22-cv-05185
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Steven Wayne Bonilla v. Humboldt County Superior Court et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice because filing-fee rules and other legal bars applied.

Who this affects

Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The cases named several state courts, state judges, and state and federal officials as defendants.

What happened

Steven Wayne Bonilla v. Humboldt County Superior Court et al. involved multiple civil-rights complaints filed by Bonilla, a state prisoner, against courts, judges, and other officials. He challenged his conviction and the handling of his other cases.

The court said Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status, and his complaints did not show that he faced an immediate threat of serious physical injury when he filed them. The court also said the lawsuits would be barred for additional legal reasons, even if he had been allowed to proceed without paying fees.

Judge Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in them without filing them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
v. Bonilla · No. 4:22-cv-05185
Judge
Phyllis Hamilton
Date
Sept. 19, 2022

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government actors. The complaints named several state courts, state judges, and state and federal officials. Bonilla sought relief concerning his underlying conviction and the way state and federal courts handled his other cases. The order lists these case numbers: 22-cv-5122-PJH, 22-cv-5124-PJH, 22-cv-5132-PJH, 22-cv-5133-PJH, 22-cv-5134-PJH, 22-cv-5185-PJH, 22-cv-5186-PJH, 22-cv-5187-PJH, 22-cv-5210-PJH, and 22-cv-5211-PJH.

The order states that Bonilla presented nearly identical claims in the cases. It also states that he had a pending federal petition concerning his imprisonment in this court with appointed counsel and was represented by counsel in state-court proceedings concerning his imprisonment.

Filing-fee status and legal bars

To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from that status unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger.

The court further stated that, even if Bonilla had been allowed to proceed without paying filing fees, the lawsuits would be barred under several legal doctrines and decisions cited in the order: 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 validity of Bonilla's civil-rights claims.

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 on September 19, 2022.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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