Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:24-cv-02438
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. State of California, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice, and the defendants in those cases were no longer required to litigate them in the district court.
What happened
In Steven Wayne Bonilla v. State of California, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against state courts and agencies. He challenged his conviction and the handling of other cases by state and federal courts.
The court found that Bonilla did not show he faced an immediate threat of serious physical injury when he filed the complaints. Because of his prior cases, he could not proceed without paying the filing fees unless that exception applied. The court also said the lawsuits would be barred by several legal rules even if he were allowed to proceed without paying.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:24-cv-02438
- Phyllis Hamilton
- Apr. 29, 2024
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. Bonilla named various state courts and agencies as defendants and sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The order notes that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was also represented by counsel in state-court proceedings. The court further noted Bonilla's extensive history of filing similar cases.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee because of his prior cases. That restriction has an exception if a prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such imminent danger. Bonilla therefore could not proceed without paying the filing fee.
Other Grounds for Dismissal
The court 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 order does not provide a separate claim-by-claim analysis explaining which cited rule applied to which complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis Hamilton on April 29, 2024.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.