Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:22-cv-07517
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Contra Costa County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla and the defendants named in the multiple cases, including various state superior courts and state judges.
What happened
In Bonilla v. Contra Costa County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases against state superior courts and judges. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an immediate serious physical danger. The complaints did not show that danger. The court also said that, even if Bonilla could proceed without paying fees, legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton ordered the clerk to return any further documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:22-cv-07517
- Phyllis Hamilton
- Dec. 27, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists these case numbers: 22-cv-7498-PJH, 22-cv-7516-PJH, 22-cv-7517-PJH, 22-cv-7546-PJH, 22-cv-7547-PJH, 22-cv-7548-PJH, 22-cv-7549-PJH, 22-cv-7711-PJH, 22-cv-7712-PJH, 22-cv-8982-PJH, 22-cv-8983-PJH, 22-cv-8984-PJH, 22-cv-9055-PJH, and 22-cv-9100-PJH.
The complaints were nearly identical. Bonilla named various state superior courts and state judges as defendants and sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. The opinion also states that he had a pending federal petition concerning his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified from proceeding without paying fees under that provision and that his allegations did not show the required danger.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under rules and doctrines identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
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.
Classification note
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and legal bars without deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.