Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:22-cv-06519
- 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 his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named county clerk and state superior court defendants were affected by the case closures.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against county clerks and state superior courts. He challenged his conviction and how other cases were handled by state and federal courts.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred by legal rules concerning challenges to convictions, interference with ongoing state proceedings, and federal court decisions. The cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
Judge Phyllis J. Hamilton issued the order on October 28, 2022.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:22-cv-06519
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named numerous county clerks and state superior courts as defendants. The court said the cases presented nearly identical claims concerning Bonilla’s underlying conviction and the handling of his other cases by state and federal courts.
The order covered multiple case numbers, including 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.
Court’s analysis
The Prison Litigation Reform Act generally prevents a prisoner who has repeatedly filed actions dismissed as legally or factually deficient from proceeding without paying the filing fee. Under 28 U.S.C. § 1915(g), an exception applies if the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that provision and that his allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without paying 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 order did not provide a separate claim-by-claim explanation of which cited rule applied to each case.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the 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.