Bonilla v. County of Mendocino
- Phyllis Hamilton
- 4:23-cv-04167
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Clara County Superior Court, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and the lawsuits were barred.
Steven Wayne Bonilla's multiple civil-rights cases and the state-court and municipal defendants named in them.
What happened
Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases under 42 U.S.C. § 1983 against various state courts and municipalities. He sought relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because he was disqualified from fee-free filing under a federal law and had not shown that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if fee-free filing had been allowed, the lawsuits would be barred by several legal doctrines and precedents.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. County of Mendocino · No. 4:23-cv-04167
- Phyllis Hamilton
- Aug. 28, 2023
Background
Steven Wayne Bonilla, described as a state prisoner and condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various state courts and municipalities as defendants and sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was also represented by counsel in state-court proceedings. The opinion does not resolve those other proceedings.
Fee-free filing status
The court addressed Bonilla’s possible requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding without fees unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fees.
Other stated barriers
The court further stated that, even if an application to proceed without fees 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 does not separately explain which doctrine applied to which complaint or claim.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk 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 on August 28, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.