Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:22-cv-06123
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Madera County Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits against county clerks and state superior courts were dismissed with prejudice; the court also closed the cases and directed the clerk to return later submissions without filing.
What happened
In Bonilla v. Madera County Court Clerk’s Office, 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 how other courts handled his cases.
The court found that Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees and did not show that he faced an immediate danger of serious physical injury. The court also stated that the lawsuits would be barred by several legal rules even if his fee applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that future documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:22-cv-06123
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the following case numbers: 22-cv-5602-PJH, 22-cv-6123-PJH, 22-cv-6240-PJH, 22-cv-6399-PJH, 22-cv-6400-PJH, 22-cv-6478-PJH, 22-cv-6479-PJH, 22-cv-6510-PJH, 22-cv-6514-PJH, 22-cv-6519-PJH, 22-cv-6528-PJH, 22-cv-6556-PJH, 22-cv-6557-PJH, 22-cv-6558-PJH, 22-cv-6559-PJH, 22-cv-6568-PJH, 22-cv-6569-PJH, 22-cv-6570-PJH, 22-cv-6571-PJH, 22-cv-6572-PJH, 22-cv-6574-PJH, and 22-cv-6575-PJH.
The complaints presented nearly identical claims and named numerous county clerks and state superior courts as defendants. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The order also states that he had a pending federal petition concerning his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Reasons for dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a prisoner with that disqualification to proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying the fee were granted, the lawsuits would be barred under rules identified in the order, including the rule from Heck v. Humphrey, the rule requiring federal courts to refrain from interfering with certain ongoing state proceedings under Younger v. Harris, and other authorities cited by the court. The order did not provide separate claim-by-claim analysis of those barriers.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed 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.