Bonilla
- Phyllis Hamilton
- 4:23-cv-03911
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Santa Clara County Superior Court, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without fees and his lawsuits faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases against Santa Clara County Superior Court and the other named defendants were dismissed with prejudice and closed.
What happened
Steven Wayne Bonilla filed multiple civil-rights lawsuits under a federal law allowing claims against government officials. He sued Santa Clara County Superior Court and other defendants over his conviction and how other courts handled his cases.
Bonilla was a state prisoner and filed these lawsuits without a lawyer. The court said he had previously lost the ability to proceed without prepaying filing fees unless he showed an imminent danger of serious physical injury, and his allegations did not show that danger.
Judge Phyllis J. Hamilton ruled that the lawsuits were also barred by several legal doctrines, including rules concerning challenges to convictions and interference with ongoing court proceedings. She dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future filings without filing them.
The detailed version
- Bonilla · No. 4:23-cv-03911
- Phyllis Hamilton
- Aug. 28, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The complaints were nearly identical. They named various state courts and municipalities as defendants and sought relief concerning Bonilla’s underlying conviction and the handling of his other cases in state and federal court.
The order noted that Bonilla had a pending federal petition challenging his conviction in the same district, with appointed counsel, and was represented by counsel in state court proceedings concerning that petition.
Proceeding Without Prepaying Fees
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without prepaying filing fees unless he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without prepaying the filing fees.
Other Legal Bars and Disposition
The court further stated that, even if an application to proceed without prepaying 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 order did not provide separate claim-by-claim rulings for the multiple complaints.
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and 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.