Bonilla
- Phyllis Hamilton
- 4:22-cv-05211
- 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 because Bonilla could not proceed without filing fees and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, affecting his claims against the state courts, judges, and state and federal officials he named as defendants.
What happened
Steven Wayne Bonilla, a state prisoner, filed several nearly identical lawsuits without a lawyer under a federal civil-rights law. He sued state courts, judges, and state and federal officials, seeking relief related to his conviction and how other court cases were handled.
The court said Bonilla was barred from proceeding without prepaying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not show such a danger. The court also said that, even if he were allowed to proceed without prepaying fees, the lawsuits would be barred by several legal rules. It dismissed the cases with prejudice, closed them, terminated pending motions, and directed the clerk to return future filings without filing them.
Judge Phyllis J. Hamilton issued the order on September 19, 2022.
The detailed version
- Bonilla · No. 4:22-cv-05211
- Phyllis Hamilton
- Sept. 19, 2022
Background
Steven Wayne Bonilla, identified in the order as a state prisoner and a condemned prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against government actors. The cases presented nearly identical claims against several state courts, state judges, and state and federal officials. Bonilla sought relief concerning his underlying conviction or the handling of his other state and federal cases. The order also notes that he had a pending federal petition with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee ruling
The court explained that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without prepaying the filing fee, under 28 U.S.C. § 1915(g). That restriction applies unless the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show imminent danger at the time of filing. As a result, Bonilla could not proceed in forma pauperis in these cases.
Other grounds for dismissal
The court further stated that, even if an application to proceed in forma pauperis were granted, the lawsuits would be barred under the rules 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 therefore dismissed the cases with prejudice. It did not resolve the underlying claims in Bonilla's favor or against him on their merits; it dismissed the cases based on the filing-fee restriction and the cited legal bars.
Disposition
The court dismissed all of the listed 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.