Bonilla v. Santa Cruz Superior Court
- Phyllis Hamilton
- 4:24-cv-02254
- U.S. District Court · Northern District of California
- 2
In Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed under the filing-fee waiver and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the named state courts and agencies as defendants and directed the clerk’s handling of future filings in the closed cases.
What happened
In Steven Wayne Bonilla v. State of California, Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights cases against state courts and agencies. He challenged his conviction and the handling of his other cases.
The court found that Bonilla did not show an immediate danger of serious physical injury when he filed, so he could not proceed under the filing-fee waiver. The court also said that, even if a fee waiver were granted, the lawsuits would be barred under four cited legal rules. It dismissed the cases with prejudice, ended all pending motions, and closed the cases.
Judge Phyllis Hamilton ordered the clerk to return, without filing, any further documents Bonilla submits in the closed cases.
The detailed version
- Bonilla v. Santa Cruz Superior Court · No. 4:24-cv-02254
- Phyllis Hamilton
- Apr. 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various state courts and agencies as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The order notes that Bonilla also had a pending federal petition challenging his confinement in the same district, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee waiver
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced an immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such a danger. Bonilla therefore could not proceed under the filing-fee waiver.
Other grounds for dismissal
The court further stated that, even if a filing-fee waiver had been granted, the lawsuits would be barred under the rules and precedents cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those grounds.
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 submits in the closed cases. Judge Phyllis Hamilton additionally noted Bonilla’s history of filing similar cases and described it as extensive.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.