Bonilla
- Phyllis Hamilton
- 4:23-cv-04169
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Clara County Superior Court, Judge Hamilton dismissed with prejudice nine similar prisoner civil-rights cases because Bonilla could not proceed without paying and the suits were barred.
Steven Wayne Bonilla's nine civil-rights cases were dismissed with prejudice; the named state courts and municipalities were defendants in those cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed nine similar civil-rights lawsuits against various state courts and municipalities. He sought relief related to his conviction and 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. The complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and court decisions.
Judge Phyllis J. Hamilton dismissed all nine cases with prejudice, directed the clerk to close them and terminate pending motions, and ordered that further documents submitted in those closed cases be returned without filing.
The detailed version
- Bonilla · No. 4:23-cv-04169
- Phyllis Hamilton
- Aug. 28, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion says he is a condemned prisoner who also has a pending federal petition challenging his custody in the same district, with appointed counsel, and state-court proceedings in which he is represented by counsel.
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.
Ruling
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 proceeding without payment may do so only if the complaint shows that he faced an imminent danger of serious physical injury when he filed it. The court found that these complaints did not show such danger, so Bonilla could not proceed without paying.
The court further stated that, even if an application to proceed without payment were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, concerning certain civil claims that would undermine a conviction; Younger v. Harris, concerning federal interference with ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return without filing any additional 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.