Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:22-cv-09116
- 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 Bonilla could not proceed without paying fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The court closed the cases, terminated pending motions, and directed the clerk to 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 several nearly identical civil-rights cases against state superior courts and judges. He challenged his conviction and how other state and federal court proceedings were handled.
The court found that Bonilla was barred from proceeding without paying filing fees because his allegations did not show imminent danger of serious physical injury. The court also said the lawsuits would be barred for other reasons even if he could proceed without paying fees, and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. The clerk was also directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:22-cv-09116
- Phyllis Hamilton
- Jan. 13, 2023
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers cases numbered 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 court described Bonilla as a condemned prisoner who also had a pending federal petition challenging his detention or conviction, with appointed counsel, and state-court proceedings in which he was represented by counsel. In these cases, he presented nearly identical claims against various state superior courts and state judges. He sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.
Court’s Analysis
The court addressed Bonilla’s possible requests to proceed without paying the filing fees, a status commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without paying fees unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate explanation applying each cited rule to each case.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and other threshold legal barriers rather than deciding the underlying challenges to Bonilla’s conviction or the handling of his other proceedings.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.