Bonilla v. Alameda County District Attorney
- Phyllis Hamilton
- 4:22-cv-07479
- U.S. District Court · Northern District of California
- 2
Bonilla v. Napa County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, preventing those cases from continuing. The named state courts and officials were no longer required to litigate these closed cases.
What happened
In Bonilla v. Napa County Superior Court and related cases, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights lawsuits against state courts and officials involved in his criminal prosecution.
Bonilla sought relief related to his conviction and the way other state and federal court cases had been handled. The court said he was barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury, and his allegations did not make that showing.
The court also said the lawsuits would be barred even if his fee applications were granted, relying on several legal doctrines. Judge Phyllis 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. Alameda County District Attorney · No. 4:22-cv-07479
- Phyllis Hamilton
- Nov. 29, 2022
Background
Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named state superior courts and officials involved in his criminal prosecution. The court described the claims as nearly identical and said they sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The opinion also noted that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings challenging his conviction.
Court’s Analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying fees may proceed that way only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court further stated that, even if Bonilla’s applications to proceed without paying fees 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 did not separately analyze which specific doctrine applied to each case or claim.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and 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.