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N.D. Cal.Procedural orderFiled Jan. 13, 2023

Bonilla v. Humboldt County Superior Court

Judge
Phyllis Hamilton
Docket
4:22-cv-09117
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and legal barriers.

Who this affects

Steven Wayne Bonilla and the defendants named in the multiple cases, including state superior courts and state judges.

What happened

In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed several nearly identical civil-rights lawsuits against state superior courts and judges. He challenged his conviction and the handling of other cases in state and federal court.

The court ruled that Bonilla could not proceed without paying the filing fee because his complaints did not show imminent danger of serious physical injury. The court also said the lawsuits would be barred by several legal doctrines even if his applications to proceed without paying were granted. It dismissed the cases with prejudice, terminated all pending motions, and closed the cases.

Judge Phyllis J. Hamilton issued the order on January 13, 2023. The clerk was directed to return without filing any further documents Bonilla submitted in the closed cases.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Humboldt County Superior Court · No. 4:22-cv-09117
Judge
Phyllis Hamilton
Date
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 presented nearly identical claims and named various state superior courts and state judges as defendants. The order says Bonilla sought relief concerning his underlying conviction or the way other cases had been handled by state and federal courts.

The order also notes that Bonilla had a pending federal petition challenging his imprisonment in this court with appointed counsel and was represented by counsel in state-court proceedings concerning the same general subject matter.

Proceeding Without Paying the Filing Fee

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), 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 such imminent danger. It therefore ruled that Bonilla could not proceed without paying the filing fee.

Other Grounds for Dismissal

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 legal 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 analysis of how each doctrine applied 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 to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order on January 13, 2023.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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