Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:23-cv-00034
- U.S. District Court · Northern District of California
- 2
Bonilla v. El Dorado County Superior Court: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla and his multiple civil-rights cases against the state and federal court-related defendants named in the complaints.
What happened
In Bonilla v. El Dorado County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed several nearly identical civil-rights cases. He challenged his conviction and the handling of other cases by state and federal courts.
Bonilla named state superior courts, state judges, and federal judges as defendants. He sought permission to file without paying court fees, but the court said his allegations did not show that he faced an immediate danger of serious physical injury when he filed.
Judge Phyllis J. Hamilton dismissed the cases with prejudice. She also directed the clerk to end all pending motions, close the cases, and return any additional documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:23-cv-00034
- Phyllis Hamilton
- Jan. 27, 2023
Background
Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order addresses these case numbers: 23-cv-0031-PJH, 23-cv-0032-PJH, 23-cv-0033-PJH, 23-cv-0034-PJH, 23-cv-0068-PJH, 23-cv-0254-PJH, 23-cv-0356-PJH, 23-cv-0357-PJH, 23-cv-0358-PJH, 23-cv-0359-PJH, and 23-cv-0360-PJH.
The complaints presented nearly identical claims against various state superior courts, state judges, and federal judges in the Eastern District of California. Bonilla sought relief concerning his underlying conviction or the way state and federal courts had handled his other cases. The order also notes that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
Bonilla sought, or potentially sought, permission to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the qualifying prior dismissals cannot proceed without prepaying the filing fee unless the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified from proceeding without prepaying the fee and that his allegations did not show the required danger.
Other legal bars
The court further stated that, even if Bonilla were allowed to proceed without prepaying the fee, 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 separate claim-by-claim analysis of those doctrines.
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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.