Bonilla v. Villareal
- Phyllis Hamilton
- 4:22-cv-06478
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Villareal, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla's multiple § 1983 lawsuits against county clerks and state superior courts were dismissed with prejudice; the court also barred him from proceeding without paying filing fees in these cases.
What happened
In Bonilla v. Villareal, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against county clerks and state superior courts. He challenged his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without payment and had not shown that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he could proceed without paying, legal rules would bar the lawsuits.
Judge Phyllis Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that additional documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Villareal · No. 4:22-cv-06478
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute. He represented himself in these cases. The complaints named numerous county clerks and state superior courts as defendants and raised nearly identical claims. The opinion states that Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The opinion also notes that Bonilla had a pending federal petition challenging his custody in the same district, with appointed counsel, and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner with qualifying prior dismissals from proceeding without paying unless the prisoner shows that he was in immediate danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show that Bonilla faced such danger at the time of filing. It therefore concluded that he could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further ruled that, even if an application to proceed without paying fees were granted, the lawsuits would still be barred under the legal 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 provide a separate claim-by-claim analysis of those rules.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Judge Phyllis J. Hamilton signed the order on October 28, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.