Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:22-cv-06926
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Napa County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and his claims were legally barred.
Steven Wayne Bonilla's nine listed civil-rights cases were dismissed with prejudice; the order also affected the state superior courts and officials named as defendants in those cases.
What happened
In Bonilla v. Napa County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state superior courts and officials involved in his criminal prosecution.
Bonilla sought relief related to his conviction and to how state and federal courts handled his other cases. The court said he had been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed, and his complaints did not show that risk.
The court also said that, even if Bonilla could proceed without paying fees, several legal rules would bar the lawsuits. Judge Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:22-cv-06926
- Phyllis Hamilton
- Nov. 29, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law that allows civil-rights claims against state actors. He represented himself. The complaints were nearly identical and named state superior courts and officials involved in his criminal prosecution. They sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal cases.
The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings. The court did not provide a separate claim-by-claim analysis for each complaint.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was under an imminent danger of serious physical injury when he filed his complaint. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under several legal doctrines. It cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not explain separately how each cited doctrine applied to each complaint.
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. 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.