Bonilla v. Del Norte Superior Court
- Phyllis Hamilton
- 4:22-cv-06974
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Napa County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not show imminent danger and the suits were barred.
Steven Wayne Bonilla's multiple self-represented civil-rights cases were dismissed with prejudice, affecting his claims against the state superior courts and officials he named as defendants.
What happened
Steven Wayne Bonilla v. Napa County Superior Court involved multiple nearly identical civil-rights complaints filed by Bonilla, a state prisoner representing himself. He named state superior courts and officials involved in his criminal prosecution and sought relief concerning his conviction and the handling of other cases by state and federal courts.
The court said Bonilla had previously been disqualified from proceeding without paying the filing fee unless he showed that he faced an imminent danger of serious physical injury when he filed. The court found that his allegations did not show such danger. It also said that, even if he were allowed to proceed without paying the fee, the lawsuits would be barred by several legal doctrines concerning challenges to convictions, ongoing state proceedings, and restrictions on suing federal courts.
The court dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future filings without filing them. Judge Phyllis J. Hamilton signed the order.
The detailed version
- Bonilla v. Del Norte Superior Court · No. 4:22-cv-06974
- Phyllis Hamilton
- Nov. 29, 2022
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. Bonilla named state superior courts and officials involved in his criminal prosecution. The opinion says he sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases.
The opinion also notes that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same district, where he had appointed counsel. It says he was also represented by counsel in state-court proceedings challenging his custody.
Proceeding Without Paying the Filing Fee
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations in these complaints did not show imminent danger. As a result, Bonilla could not proceed without paying the filing fee.
Other Grounds for Dismissal
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 analyze each doctrine separately or identify which doctrine applies to each complaint. In general terms, the cited authorities concern restrictions on using a civil-rights action to challenge a conviction, federal-court limits related to ongoing state proceedings, and limits on certain suits against federal courts.
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 additional documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.