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N.D. Cal.Procedural orderFiled Dec. 27, 2022

Bonilla v. Sonoma County Superior Court

Judge
Phyllis Hamilton
Docket
4:22-cv-07516
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. Contra Costa County Superior Court, Judge Hamilton dismissed the civil-rights cases with prejudice because Bonilla showed no imminent danger and the suits faced other legal bars.

Who this affects

Steven Wayne Bonilla and the state superior courts and judges he sued; all listed cases were closed.

What happened

In Bonilla v. Contra Costa County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical lawsuits without a lawyer against state superior courts and judges. He sought relief related to his conviction and the handling of his other cases.

The court found that Bonilla could not proceed without paying filing fees because he had not shown that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if it allowed him to proceed without paying, other legal barriers would prevent the lawsuits.

The court dismissed all of the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton signed the order on December 27, 2022, and directed the clerk to return any further filings in the closed cases without filing them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Sonoma County Superior Court · No. 4:22-cv-07516
Judge
Phyllis Hamilton
Date
Dec. 27, 2022

Background

Steven Wayne Bonilla, identified as a state prisoner and a prisoner sentenced to death, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The defendants included various state superior courts and state judges. The complaints presented nearly identical claims and sought relief concerning Bonilla's underlying conviction or the handling of his other cases by state and federal courts.

The opinion also states that Bonilla had a pending federal petition challenging his confinement with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and other barriers

To the extent Bonilla sought permission to proceed without paying filing fees, the court found that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was in imminent danger of serious physical injury when he filed the complaints. The court concluded that the 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 the legal rules and decisions cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court did not decide the underlying validity of Bonilla's claims.

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 additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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