Bonilla v. Lake County Superior Court Judge Andrew S. Blum
- Phyllis Hamilton
- 4:22-cv-09101
- 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 after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla's ten civil-rights cases were dismissed with prejudice. The cases named various state superior courts and state judges as defendants; the order also directed the clerk to close the cases, terminate pending motions, and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Santa Cruz County Superior Court et al., Bonilla filed multiple civil-rights lawsuits without a lawyer against state superior courts and judges. He sought relief related to his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not make that showing.
The court also said the lawsuits would be barred even if Bonilla were allowed to proceed without paying the fee, citing several legal doctrines. Judge Hamilton dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return later documents without filing them.
The detailed version
- Bonilla v. Lake County Superior Court Judge Andrew S. Blum · No. 4:22-cv-09101
- Phyllis Hamilton
- Jan. 13, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases were assigned the following numbers: 22-cv-9099-PJH, 22-cv-9101-PJH, 22-cv-9115-PJH, 22-cv-9116-PJH, 22-cv-9117-PJH, 22-cv-9118-PJH, 22-cv-9119-PJH, 22-cv-9120-PJH, 22-cv-9127-PJH, and 22-cv-9147-PJH.
The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody, for which he had appointed counsel. It also states that he was represented by counsel in state-court proceedings. The complaints presented nearly identical claims against various state superior courts and state judges. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other stated grounds
The court added that, even if an application to proceed without paying the filing fee were granted, the lawsuits would still be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those doctrines.
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. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.