Bonilla v. San Mateo Superior Court of California
- Phyllis Hamilton
- 4:24-cv-02308
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and the suits faced legal bars.
Steven Wayne Bonilla's multiple § 1983 cases were dismissed with prejudice; the named state courts and agencies were the defendants.
What happened
In Steven Wayne Bonilla v. State of California, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against various state courts and agencies. He challenged his conviction and the handling of other cases in state and federal courts.
The court said Bonilla was barred from proceeding without paying filing fees because he had previously filed qualifying cases and did not show that he faced an imminent danger of serious physical injury when he filed these complaints. The court also said that, even if he were allowed to proceed without fees, legal doctrines would bar the lawsuits.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis Hamilton also ordered the clerk to return any further documents Bonilla submits in these closed cases without filing them.
The detailed version
- Bonilla v. San Mateo Superior Court of California · No. 4:24-cv-02308
- Phyllis Hamilton
- Apr. 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a law that allows claims against state actors for violating federal rights. The complaints were filed without a lawyer and named various state courts and agencies as defendants. The court said the complaints presented nearly identical claims concerning Bonilla's underlying conviction or the way his other cases had been handled by state and federal courts.
The order covered the related cases numbered 24-cv-2153-PJH, 24-cv-2180-PJH, 24-cv-2181-PJH, 24-cv-2182-PJH, 24-cv-2239-PJH, 24-cv-2241-PJH, 24-cv-2242-PJH, 24-cv-2243-PJH, 24-cv-2254-PJH, 24-cv-2261-PJH, 24-cv-2308-PJH, 24-cv-2437-PJH, 24-cv-2438-PJH, and 24-cv-2439-PJH.
Court's reasoning
The court explained that 28 U.S.C. § 1915(g) disqualifies a prisoner from proceeding in a case without prepaying the filing fee after qualifying prior filings, unless the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such an imminent danger. As a result, he could not proceed without prepaying the filing fee.
The court further stated that, even if Bonilla's request to proceed without prepaying fees were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court did not decide the underlying merits of Bonilla's challenges to his conviction or to the handling of his other cases.
The order also noted that Bonilla had an extensive history of filing similar cases. In a footnote, Judge Hamilton stated that she was the fourth judge assigned to cases filed by Bonilla and that, since April 30, 2020, she had issued the 62nd order concerning 840 different cases. The footnote also stated that Bonilla had filed 962 other cases with the three other judges since 2011.
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 these closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.