Bonilla v. Superior Court of the State of California, County of Del Norte
- Phyllis Hamilton
- 4:24-cv-02180
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. State of California et al., Judge Hamilton dismissed multiple federal civil-rights cases with prejudice, citing filing-fee restrictions and other legal bars.
Steven Wayne Bonilla and the defendants in the multiple listed cases, including various state courts and agencies.
What happened
Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer under federal law. He challenged his conviction or the handling of his other state and federal cases, naming various state courts and agencies as defendants.
Bonilla had been barred from proceeding without paying filing fees unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his allegations did not show such danger. It also said the lawsuits would be barred even if he were allowed to proceed without paying fees, citing several legal doctrines.
Judge Phyllis Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return, without filing, any additional documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Superior Court of the State of California, County of Del Norte · No. 4:24-cv-02180
- Phyllis Hamilton
- Apr. 29, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims against various state courts and agencies. The order states that Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The order also notes that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee, unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations in these complaints did not show such danger. As a result, he could not proceed without paying the filing fee.
Other grounds cited
The court stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines and authorities 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 how each cited authority applied.
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.
This is a procedural dismissal rather than a decision resolving the underlying challenges to Bonilla's conviction or the handling of his other cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.