Bonilla v. County of Del Norte Superior Court
- Phyllis Hamilton
- 4:23-cv-04172
- 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 filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla's multiple § 1983 cases against the state courts and municipalities he named as defendants were dismissed with prejudice; the order also terminated pending motions and closed those cases.
What happened
In Steven Wayne Bonilla v. Santa Clara County Superior Court et al., the plaintiff, a state prisoner, filed multiple nearly identical civil-rights lawsuits against state courts and municipalities. He challenged his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he was disqualified from that process and had not shown that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and cases. It dismissed the cases with prejudice, closed them, terminated pending motions, and directed the clerk to return future submissions without filing them.
Judge Phyllis J. Hamilton issued the August 28, 2023 order. The order covers the listed related case numbers and does not decide the underlying conviction claims on their merits.
The detailed version
- Bonilla v. County of Del Norte Superior Court · No. 4:23-cv-04172
- Phyllis Hamilton
- Aug. 28, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion lists these case numbers: 23-cv-3911-PJH, 23-cv-3971-PJH, 23-cv-4160-PJH, 23-cv-4163-PJH, 23-cv-4165-PJH, 23-cv-4167-PJH, 23-cv-4169-PJH, 23-cv-4170-PJH, and 23-cv-4172-PJH.
The complaints were nearly identical. Bonilla named various state courts and municipalities as defendants and 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 with appointed counsel and was represented by counsel in state court proceedings.
Court’s reasoning
The court addressed Bonilla’s possible request to proceed in forma pauperis, meaning without paying the filing fee. It stated that he had been disqualified from using that procedure under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger.
The court further stated that, even if an application to proceed without paying the filing 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 opinion does not provide a separate analysis of how each cited authority applied to each complaint.
Disposition
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 the closed cases. Judge Phyllis J. Hamilton signed the order on August 28, 2023. The order disposed of the cases on filing-status and other legal-bar grounds rather than deciding the underlying conviction-related claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.