Bonilla v. Smith
- Phyllis Hamilton
- 4:22-cv-05186
- 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.
Steven Wayne Bonilla's multiple § 1983 cases were dismissed with prejudice. The named defendants included Humboldt County Superior Court, other state courts, state judges, and other state and federal officials.
What happened
In Bonilla v. Humboldt County Superior Court et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against state courts, state judges, and other state and federal officials. He sought relief related to his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The allegations did not show that danger. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by other legal rules concerning challenges to convictions, ongoing state proceedings, and actions involving courts and judges.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Smith · No. 4:22-cv-05186
- 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, a federal law allowing civil-rights claims against state actors. The complaints presented nearly identical claims against several state courts, state judges, and other state and federal officials. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion also states that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel. It further states that he was represented by counsel in state-court proceedings. These facts were included as background to the court's ruling; the court did not decide the merits of the claims in these cases.
Ruling
The court addressed Bonilla's ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has previously had qualifying cases dismissed generally cannot proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla's allegations did not show such a danger, so he could not proceed without paying the filing fee.
The court additionally stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain which rule applied to which claim or defendant.
Judge Phyllis J. Hamilton therefore dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.