Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:22-cv-09099
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Cruz County Superior Court, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and applying filing bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk to return future submissions without filing them.
What happened
In Bonilla v. Santa Cruz County Superior Court, Steven Wayne Bonilla filed several nearly identical civil-rights lawsuits against state superior courts and judges. He sought relief concerning his conviction and the way other state and federal cases were handled.
Bonilla sought permission to proceed without paying filing fees, but the court said he was barred from doing so unless he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger.
Judge Phyllis J. Hamilton also ruled that, even if Bonilla could proceed without paying fees, the lawsuits were barred by several legal doctrines and dismissed the cases with prejudice. The clerk was ordered to close the cases and return future submissions without filing them.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:22-cv-09099
- Phyllis Hamilton
- Jan. 13, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that permits claims against state actors for constitutional violations. The complaints presented nearly identical claims and named various state superior courts and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts.
The opinion also states that Bonilla was a condemned prisoner with a pending federal petition in the same court in which he had appointed counsel. It further states that he was represented by counsel in state-court proceedings.
Filing-fee status
Bonilla sought, or potentially sought, permission to proceed without paying the filing fee. The court held that he was disqualified from proceeding without paying under 28 U.S.C. § 1915(g), unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing. The opinion therefore states that Bonilla could not proceed without paying the filing fee.
Other grounds for dismissal
The court additionally stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the doctrines and authorities identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain which doctrine applied to which claim or 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 further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Classification
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal bars rather than deciding whether Bonilla's underlying civil-rights claims were valid.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.