Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:22-cv-05122
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Humboldt County Superior Court, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims faced legal bars.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the named state courts, judges, and other officials were no longer required to litigate these cases.
What happened
In Bonilla v. Humboldt County Superior Court, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state courts, judges, and other officials. He sought relief concerning his conviction and the handling of his other state and federal cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury, and his complaints did not make that showing. The court also said that, even if he could proceed without paying, the lawsuits would be barred by other legal rules. It dismissed the cases with prejudice, ended pending motions, and closed the cases.
Judge Phyllis J. Hamilton issued the order on September 19, 2022. The opinion does not separately explain the disposition of each individual claim, but it orders dismissal of the multiple cases identified by their case numbers.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:22-cv-05122
- Phyllis Hamilton
- Sept. 19, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases had nearly identical claims. Bonilla named several state courts, state judges, and other 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 also notes that Bonilla had a pending federal petition concerning his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment. Those proceedings were cited as related matters.
Court’s reasoning
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying the fee unless, when the complaint was filed, the prisoner was in immediate danger of serious physical injury. The court stated that Bonilla had been disqualified from proceeding without paying under that provision and that his allegations did not show the required immediate danger.
The court further stated that, even if an application to proceed without paying the filing fee 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 does not provide a separate claim-by-claim explanation of which cited rule applied to which complaint.
Disposition
The court dismissed the multiple cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on September 19, 2022.
Classification basis
This is a procedural order. The court disposed of the cases based on prisoner filing-fee restrictions and other threshold legal bars rather than deciding the underlying challenges to Bonilla’s conviction or the handling of his other cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.