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N.D. Cal.Procedural orderFiled Aug. 28, 2023

Bonilla v. Santa Clara County Superior Court, it's judges and clerks

Judge
Phyllis Hamilton
Docket
4:23-cv-03971
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

Bonilla v. Santa Clara County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his lawsuits faced legal bars.

Who this affects

Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected any pending motions and later documents submitted in those closed cases.

What happened

In Bonilla v. Santa Clara County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against state courts and municipalities. He sought relief concerning his conviction and the handling of his other cases by state and federal courts.

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 allegations did not show that danger. The court also said the lawsuits would be barred even if his requests to proceed without paying were granted, citing several legal doctrines and prior decisions.

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

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Santa Clara County Superior Court, it's judges and clerks · No. 4:23-cv-03971
Judge
Phyllis Hamilton
Date
Aug. 28, 2023

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical. They named various state courts and municipalities as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.

The order notes that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody.

Proceeding Without Paying Filing Fees

To the extent Bonilla sought permission to proceed without paying the filing fees, the court applied 28 U.S.C. § 1915(g). That provision disqualifies a prisoner from proceeding without paying after qualifying prior cases, unless the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court concluded that Bonilla’s allegations did not show such danger. The order therefore stated that he could not proceed without paying the filing fees.

Other Bars Identified by the Court

The court further stated that, even if an application to proceed without paying 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 order did not separately explain how each cited doctrine applied to each complaint.

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 Judge Phyllis J. Hamilton.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

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