Bonilla v. Lake County
- Phyllis Hamilton
- 4:23-cv-00357
- 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 fee-waiver rules and other legal barriers applied.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed and closed; pending motions were terminated, and later documents in those cases were to be returned without filing.
What happened
In Bonilla v. El Dorado County Superior Court, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases. He sued state superior courts, state judges, and federal judges over his conviction and how other cases had been handled.
The court found that Bonilla could not proceed without paying the filing fees because he had previously been barred from that fee-waiver status and his complaints did not show an immediate danger of serious physical injury. The court also said that, even if he had been allowed to proceed without fees, the lawsuits would be barred under several legal rules cited in the order.
The court dismissed the cases with prejudice, terminated all pending motions, closed the cases, and ordered that later documents be returned without filing. Judge Phyllis J. Hamilton issued the order.
The detailed version
- Bonilla v. Lake County · No. 4:23-cv-00357
- Phyllis Hamilton
- Jan. 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against certain government actors. The complaints were nearly identical. They named various state superior courts, state judges, and federal judges in the Eastern District of California. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.
The order also notes that Bonilla had a pending federal petition challenging his confinement in the same court with appointed counsel and was represented by counsel in state-court proceedings.
Fee-Waiver Status
Bonilla sought, or might have sought, permission to proceed without paying filing fees. The court held that 28 U.S.C. § 1915(g) disqualified him from that status unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
Other Barriers
The court further stated that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under the legal rules 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 decide the merits of Bonilla's challenges to his conviction or to the handling of his other cases.
Ruling
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. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.