Bonilla v. Contra Costa Superior Court
- Phyllis Hamilton
- 4:22-cv-08982
- U.S. District Court · Northern District of California
- 2
Bonilla v. Contra Costa Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without prepaying fees and citing procedural bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named state courts and state judges were defendants in those cases.
What happened
In Bonilla v. Contra Costa Superior Court, Steven Wayne Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights lawsuits under a federal law allowing claims against state officials and entities. He sued state superior courts and judges over his conviction and how his other cases had been handled.
The court found that Bonilla had previously been barred from proceeding without prepaying filing fees unless he showed an immediate danger of serious physical injury. The court said his complaints did not show that danger. It also said the lawsuits would be barred even if he could proceed without prepaying fees, citing several legal rules and earlier cases.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents without filing them.
The detailed version
- Bonilla v. Contra Costa Superior Court · No. 4:22-cv-08982
- Phyllis Hamilton
- Dec. 27, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various state superior courts and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his cases by state and federal courts.
The opinion also states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state proceedings involving a similar type of petition.
Filing-Fee Eligibility
The court addressed Bonilla’s requests, or possible requests, to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from doing so 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. Accordingly, Bonilla could not proceed without prepaying filing fees.
Other Bars Identified by the Court
The court further stated that, even if a request to proceed without prepaying fees 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 specify which cited bar applies to which individual case or claim.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.