Bonilla v. First Appellate District Court
- Phyllis Hamilton
- 4:23-cv-04170
- 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 fees and other legal bars applied.
Steven Wayne Bonilla and the multiple civil-rights cases he filed; the order also terminated the pending motions and closed those cases.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer against state courts and municipalities. He sought relief concerning 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 under the federal filing-fee statute and had not shown imminent danger of serious physical injury when he filed. The court also stated that, even if he could proceed without paying fees, the cases would be barred under several legal rules and cases it cited. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis J. Hamilton issued the order on August 28, 2023, and directed the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. First Appellate District Court · No. 4:23-cv-04170
- 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 without a lawyer. 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 state and federal courts handled his other cases.
Filing-fee ruling
The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the required filing fees, under 28 U.S.C. § 1915(g). The statute permits an exception when a prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the complaints did not show such imminent danger. Bonilla therefore could not proceed without paying the filing fees.
Other stated barriers and disposition
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 separate analyses of those authorities. The court dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that any further documents Bonilla submitted in the closed cases be returned without filing.
Judge Phyllis J. Hamilton signed the order on August 28, 2023.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.