Bonilla v. Claire
- Phyllis Hamilton
- 4:23-cv-00356
- 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 prepaying fees and his lawsuits were barred.
Steven Wayne Bonilla's multiple § 1983 cases were dismissed with prejudice; the order also directed the clerk to close the cases and return later submissions without filing them.
What happened
Bonilla v. El Dorado County Superior Court involved multiple civil-rights lawsuits filed by Steven Wayne Bonilla, a state prisoner, without a lawyer. He brought nearly identical cases against state superior courts, state judges, and federal judges, seeking relief related to his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without prepaying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not make that showing. The court also said that, even if he could proceed without prepaying fees, the lawsuits were barred by several legal doctrines.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton ordered the clerk to return any further documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Claire · No. 4:23-cv-00356
- Phyllis Hamilton
- Jan. 27, 2023
Background
Steven Wayne Bonilla, a state prisoner and condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers 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 order also noted that he had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state-court proceedings.
Court’s reasoning
The court ruled that Bonilla was disqualified from proceeding without prepaying the filing fee under 28 U.S.C. § 1915(g), which limits that status for a prisoner who has brought certain prior actions. The exception applies when the prisoner shows that he was under imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without prepaying the fee were 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 order did not provide a separate merits determination of Bonilla’s underlying claims.
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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.