Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:22-cv-09119
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice, citing filing-fee restrictions and several legal bars.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The named state superior courts and state judges were affected as defendants, and the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state superior courts and judges. He sought relief related to his conviction and how other cases were handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that his allegations did not make that showing. It also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal rules and earlier decisions.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton ordered the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:22-cv-09119
- Phyllis Hamilton
- Jan. 13, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. 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 other state and federal cases.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel and was represented by counsel in state court proceedings concerning his custody.
Filing-fee restriction
The court addressed Bonilla’s ability to proceed without paying the filing fee, commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without paying the fee unless he showed that he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.
Other legal bars
The court further stated that, even if an application to proceed without paying 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 separately analyze each of those authorities or identify which bar applied to which complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return without filing any further 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.