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N.D. Cal.Procedural orderFiled Apr. 29, 2024

Bonilla v. The People of the State of California

Judge
Phyllis Hamilton
Docket
4:24-cv-02261
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. State of California, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding filing restrictions and other legal bars.

Who this affects

Steven Wayne Bonilla and the defendants in the 14 listed cases; the cases were dismissed with prejudice and closed.

What happened

In Bonilla v. State of California, Steven Wayne Bonilla, a state prisoner, filed multiple self-represented civil-rights cases under Section 1983, a federal law allowing claims against state actors. The cases named state courts and agencies and challenged his conviction or the handling of his other cases.

The court found that Bonilla could not proceed without paying the filing fees because he had been barred from proceeding without prepayment unless he showed an immediate danger of serious physical injury. The court found no such danger. It also stated that, even if he could proceed without prepayment, the lawsuits were barred by several legal doctrines.

The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Hamilton ordered the clerk to return any further documents Bonilla submitted in the closed cases without filing them.

The detailed version

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

Case
Bonilla v. The People of the State of California · No. 4:24-cv-02261
Judge
Phyllis Hamilton
Date
Apr. 29, 2024

Background

Steven Wayne Bonilla, a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The order lists 14 related case numbers. Bonilla is described as a condemned prisoner who had a pending federal petition challenging his custody with appointed counsel and was also represented by counsel in state-court proceedings.

The complaints presented nearly identical claims and named various state courts and agencies as defendants. The order states that Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.

Filing-fee restriction

To the extent Bonilla sought permission to proceed without prepaying the filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court cited Bonilla's prior proceedings and found that the allegations did not show such danger. The court therefore held that he could not proceed without prepaying the filing fees.

Other legal bars

The court further stated that, even if an application to proceed without prepaying the 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 decide the underlying validity of Bonilla's claims; it dismissed the cases based on the filing restriction and these threshold legal bars.

Ruling

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 additionally noted Bonilla's extensive history of filing similar cases and described the undersigned judge's prior orders involving cases filed by him.

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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