Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:23-cv-00032
- U.S. District Court · Northern District of California
- 2
In 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 and the defendants in his multiple cases, including various state superior courts, state judges, and federal judges in the Eastern District of California.
What happened
In Bonilla v. El Dorado County Superior Court, Steven Wayne Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights cases. He sued various state superior courts, state judges, and federal judges over his conviction and how other cases were handled.
Bonilla sought to proceed without paying filing fees. The court said he was barred from doing so unless he showed that he faced an immediate danger of serious physical injury when he filed, and his complaints did not make that showing. The court also said the lawsuits would be barred for additional legal reasons even if he had been allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future submissions without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:23-cv-00032
- Phyllis Hamilton
- Jan. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases were assigned 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 his other state and federal cases had been handled. The opinion also states that he had a pending federal petition challenging his detention, with appointed counsel, and was represented by counsel in state 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 been disqualified from proceeding without paying may do so only by showing that he faced an imminent danger of serious physical injury when he filed the complaint. The court stated that Bonilla had previously been disqualified under that provision and that these complaints did not show the required danger.
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying claims in Bonilla’s favor or against him on their merits.
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 Judge Phyllis J. Hamilton.
Classification Note
This is a procedural order because the court relied on the filing-fee restriction and other threshold legal bars rather than deciding the underlying civil-rights claims. The supplied case name refers to Del Norte County Superior Court, but the opinion’s caption identifies El Dorado County Superior Court et al.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.