Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:22-cv-07546
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Contra Costa County Superior Court, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The order also ended pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against state superior courts and judges. He challenged his conviction and how other state and federal cases were handled.
The court ruled that Bonilla could not proceed without paying the filing fees because he did not show that he faced imminent danger of serious physical injury when he filed. The court also stated that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton signed the order on December 27, 2022. The clerk was instructed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:22-cv-07546
- Phyllis Hamilton
- Dec. 27, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims and named various state superior courts and state judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The order states that Bonilla had a pending federal petition challenging his imprisonment in the same court, with appointed counsel, and that he was represented by counsel in state-court proceedings. The order concerns the related cases numbered 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.
Reasoning
The court applied 28 U.S.C. § 1915(g), which generally prevents a prisoner who has had three or more qualifying cases dismissed from proceeding without paying the filing fee, unless the prisoner shows that he faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that provision and that the allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those doctrines.
Ruling and effect
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases. The opinion text identifies the defendant in the caption as “Contra Costa County Superior Court et al.”, although the supplied case name refers to Del Norte County Superior Court.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.