Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:22-cv-07548
- 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 paying filing fees.
Steven Wayne Bonilla's multiple § 1983 cases against various state superior courts and state judges were dismissed with prejudice; pending motions were terminated and the cases were closed.
What happened
Bonilla v. Contra Costa County Superior Court involved multiple nearly identical civil-rights complaints filed without a lawyer by Steven Wayne Bonilla, a state prisoner. He sued various state superior courts and judges and sought relief related to his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not make that showing. The court also said that, even if he could proceed without paying, the lawsuits were barred under several prior-court doctrines and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submitted in them.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:22-cv-07548
- Phyllis Hamilton
- Dec. 27, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He named various state superior courts and state judges as defendants. The opinion says he sought relief concerning his underlying conviction and the handling of his other state and federal court cases. It also notes that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. As a result, he could not proceed without paying the filing fee.
Additional Grounds for Dismissal
The court further stated that, even if an application to proceed without paying the filing fee 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 does not separately explain how each cited decision 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. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.