Bonilla v. Superior Court of California, County of Marin
- Phyllis Hamilton
- 4:24-cv-02181
- 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 paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return without filing any further documents submitted in those closed cases.
What happened
In Steven Wayne Bonilla v. State of California et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against various state courts and agencies. He sought relief concerning his conviction and the handling of other cases in state and federal courts.
The court ruled that Bonilla was barred from proceeding without paying the filing fee because he had been disqualified under federal law and his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and decisions, including rules concerning challenges to convictions and interference with ongoing proceedings.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis Hamilton also ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Superior Court of California, County of Marin · No. 4:24-cv-02181
- Phyllis Hamilton
- Apr. 29, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists these case numbers: 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.
The complaints presented nearly identical claims and named various state courts and agencies as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The opinion also states that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner disqualified from proceeding without paying may do so only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla’s allegations did not show such danger. As a result, he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying 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 opinion did not separately analyze each complaint or explain which cited legal bar applied to which claim.
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 submitted in the closed cases. The opinion additionally noted Bonilla’s history of filing similar cases and stated that the order was the 62nd order issued by Judge Phyllis Hamilton since April 30, 2020, concerning 840 different cases filed by him.
Classification note
This is a procedural order because the court disposed of the cases based on the filing-fee restriction and threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.