Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:23-cv-02551
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Del Norte County Superior Court, Judge Hamilton dismissed multiple federal civil-rights cases with prejudice because Bonilla showed no imminent danger and other legal bars applied.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice; the order also ended pending motions, closed the cases, and directed the clerk not to file further documents submitted in them.
What happened
In Bonilla v. Del Norte County Superior Court, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He sued state judges and court employees over his conviction and the handling of other cases.
The court said Bonilla could not proceed without paying the filing fee because he had been disqualified from proceeding without paying under federal law, and his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:23-cv-02551
- Phyllis Hamilton
- May 26, 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 complaints were nearly identical. They named various state judges and court employees as defendants and sought relief concerning Bonilla's underlying conviction or the way state and federal courts handled his other cases.
The opinion also states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in this court, where he has appointed counsel. It states that he is represented by counsel in state-court proceedings as well.
Court's analysis
The court addressed Bonilla's potential requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without paying unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger.
The court further stated that, even if Bonilla were allowed to proceed without paying, the lawsuits would be barred under the legal rules and precedents it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate explanation of how each cited authority applied to each individual case.
Ruling and effect
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
The order was signed by Judge Phyllis J. Hamilton on May 26, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.