Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:22-cv-09118
- 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 because Bonilla could not proceed without paying and the suits were legally barred.
Steven Wayne Bonilla's multiple civil-rights cases against various state superior courts and state judges were dismissed with prejudice, and he could not proceed in those cases without paying the filing fee.
What happened
Bonilla v. Santa Cruz County Superior Court involved multiple nearly identical civil-rights lawsuits filed by state prisoner Steven Wayne Bonilla against various state superior courts and state judges. He sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla was barred from proceeding without paying the filing fee because his complaints did not show imminent danger of serious physical injury. The court also said that, even if he could proceed without paying, the lawsuits were barred under several legal doctrines and authorities the court cited.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:22-cv-09118
- Phyllis Hamilton
- Jan. 13, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state actors for alleged violations of federal rights. He named various state superior courts and state judges as defendants. The complaints were nearly identical and sought relief concerning his underlying conviction or the handling of his other cases in state and federal courts.
The opinion states that Bonilla was a condemned prisoner with a pending federal petition challenging his custody in the same court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings. The court did not provide further merits analysis of the claims in these cases.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla was disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time. It therefore held that he could not proceed without paying the filing fee.
Other Grounds Cited by the Court
The court further stated that, even if an application to proceed without paying the filing fee 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 cites these authorities but does not separately explain in detail how each one applies to each complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and it ordered the clerk to return, without filing, any further documents Bonilla submitted in those closed cases. The order was signed by Judge Phyllis J. Hamilton.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and legal bars without deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.