Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:22-cv-07476
- 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 could not proceed without fees and the suits were barred.
Steven Wayne Bonilla, the plaintiff in the related cases, and the state courts and officials he sued.
What happened
In Steven Wayne Bonilla v. Napa County Superior Court and related cases, Bonilla, a state prisoner proceeding without a lawyer, filed nearly identical civil-rights lawsuits against state superior courts and officials connected to his criminal prosecution. He sought relief concerning his conviction and the handling of other cases by state and federal courts.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he faced an immediate risk of serious physical injury. The allegations did not show that such a danger existed when he filed. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by rules and precedents governing challenges to criminal convictions, ongoing state proceedings, and certain claims against courts.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:22-cv-07476
- Phyllis Hamilton
- Nov. 29, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were described as nearly identical. They named state superior courts and officials involved in his criminal prosecution and sought relief concerning his underlying conviction or the way other state and federal cases had been handled.
The order also noted that Bonilla had a pending federal petition in the same court with appointed counsel and was represented by counsel in state court proceedings. The court did not address the merits of the claims in those other proceedings.
Proceeding Without Filing Fees
The court ruled that Bonilla was disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without paying the filing fee, unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court further ruled that, even if Bonilla's request to proceed without paying fees had been granted, the lawsuits would still be barred under several precedents. These included Heck v. Humphrey, concerning civil-rights claims that would undermine a criminal conviction; Younger v. Harris, concerning federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
These were threshold grounds for ending the cases. The order did not decide whether Bonilla's underlying civil-rights allegations were legally or factually correct.
Disposition
The court dismissed all of the listed cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.