Bonilla v. Benavidef
- Phyllis Hamilton
- 4:23-cv-00254
- U.S. District Court · Northern District of California
- 2
In Bonilla v. El Dorado County Superior Court, Judge Hamilton dismissed multiple pro se civil-rights cases with prejudice because Bonilla could not proceed without prepaying fees and his lawsuits were barred.
Steven Wayne Bonilla's eleven listed civil-rights cases were dismissed with prejudice, affecting his claims against the state courts, state judges, and federal judges named as defendants. The order also terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
What happened
In Bonilla v. El Dorado County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against state courts, state judges, and federal judges. He sought relief related to his conviction and the handling of other cases.
The court ruled that Bonilla could not proceed without prepaying filing fees because he had previously been barred from using that process and had not shown that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he were allowed to proceed without prepaying fees, the lawsuits were barred by several legal doctrines and cases it cited.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and ordered the clerk to return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Benavidef · No. 4:23-cv-00254
- Phyllis Hamilton
- Jan. 27, 2023
Background
Steven Wayne Bonilla, described in the opinion as a state prisoner and a condemned 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, state judges, and federal judges in the Eastern District of California as defendants.
Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled. The opinion also notes that he had a pending federal petition with appointed counsel and was represented by counsel in state-court proceedings.
Fee-waiver ruling
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis, meaning without prepaying filing fees, unless he showed that he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore ruled that Bonilla could not proceed without prepaying the fees.
Other stated barriers
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal authorities it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each authority's application to each complaint.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order.
Classification
This is a procedural order because the court disposed of the cases based on eligibility to proceed without prepaying fees and stated threshold legal bars, rather than 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.