Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:23-cv-02745
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. United States District Court, Judge Hamilton dismissed seven civil-rights cases with prejudice because Bonilla could not proceed without fees and the suits were barred.
Steven Wayne Bonilla and his seven listed civil-rights cases; the order also directed the clerk to close those cases and reject further filings in them.
What happened
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed seven nearly identical civil-rights complaints against various federal and state courts. He sought relief concerning his conviction or the handling of his other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The allegations did not make that showing. The court also said that, even if he were allowed to proceed without fees, the lawsuits would be barred by several legal doctrines protecting the validity of criminal convictions, ongoing proceedings, and court decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:23-cv-02745
- Phyllis Hamilton
- June 27, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints presented nearly identical claims and named various federal and state courts as defendants. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. The opinion also notes that he had a pending federal petition challenging his detention 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 fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying fees only if, when the complaint was filed, he was in immediate danger of serious physical injury. The court found that the complaints did not show such danger.
The court further stated that, even if an application to proceed without paying fees 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 opinion did not provide a separate claim-by-claim analysis of those doctrines.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.