Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:22-cv-07712
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Contra Costa County Superior Court, Judge Hamilton dismissed multiple federal civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the court also terminated pending motions, closed the cases, and ordered future submissions returned without filing.
What happened
In Bonilla v. Contra Costa County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against state superior courts and judges. He challenged his conviction and how other state and federal court cases were handled.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he were allowed to proceed without paying, the lawsuits would be barred under several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in those cases without filing them.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:22-cv-07712
- Phyllis Hamilton
- Dec. 27, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. 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 and the way his other cases had been handled by state and federal courts. The opinion also notes that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state court proceedings.
Ruling
The court addressed Bonilla's ability to proceed without paying filing fees, a status commonly called in forma pauperis, or IFP. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed IFP unless he was under imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding IFP under that provision and that his allegations did not show imminent danger at the time of filing.
The court further stated that, even if an IFP application 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 provide separate claim-by-claim explanations for how each cited authority applied.
Judge Phyllis J. Hamilton therefore ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in those closed cases. The order was entered on December 27, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.