Bonilla v. Contra Costa County Superior Court
- Phyllis Hamilton
- 4:22-cv-06570
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Madera County Court Clerk’s Office, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also ended the pending motions and prevented further documents from being filed in the closed cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under a federal law allowing suits against state actors. He named county clerks and state superior courts as defendants and challenged his conviction and the handling of other cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an imminent danger of serious physical injury. The complaints did not show that danger. The court also said the lawsuits would be barred even if he were allowed to proceed without paying fees.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also ordered the clerk to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Contra Costa County Superior Court · No. 4:22-cv-06570
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, identified in the opinion as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The complaints presented nearly identical claims against numerous county clerks and state superior courts. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court.
The opinion states that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings. The court also noted that Bonilla had previously been disqualified from proceeding without paying filing fees under the federal prisoner-litigation statute, 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed the complaint.
Court’s analysis
The court held that the allegations did not show imminent danger at the time of filing. Therefore, Bonilla could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several doctrines and authorities: Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal court interference with certain ongoing state proceedings; and other authorities cited by the court concerning restrictions on challenging court proceedings.
Ruling
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those 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.