Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:23-cv-00033
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. El Dorado County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees.
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 later submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against state superior courts, state judges, and federal judges. He challenged his conviction and the handling of his other cases.
The court said Bonilla had already lost the ability to proceed without paying filing fees unless he showed that he faced an immediate serious physical danger when he filed. The complaints did not show that danger. The court also said the lawsuits would be barred by several legal rules even if he could proceed without paying.
The court dismissed all of the cases with prejudice and directed the clerk to close them and return later filings. Judge Phyllis J. Hamilton also terminated the pending motions.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:23-cv-00033
- Phyllis Hamilton
- Jan. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute allowing claims against state actors for certain constitutional violations. The complaints were filed without a lawyer and presented nearly identical claims. The defendants included various state superior courts, state judges, and federal judges in the Eastern District of California.
Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases. The opinion also states that he had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has previously had qualifying cases dismissed generally cannot proceed without paying unless the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court determined that these complaints did not show such danger.
The court further stated that, even if Bonilla’s request to proceed without paying had been granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, which can prevent civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
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. The order was signed by United States District Judge Phyllis J. Hamilton.
Classification note
This is a procedural order because the court dismissed the cases based on the prisoner filing-fee restriction and other threshold barriers rather than deciding whether Bonilla’s underlying civil-rights allegations were legally valid.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.