Bonilla v. Court Clerk Supervisor
- Phyllis Hamilton
- 4:20-cv-03655
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Court Clerk Supervisor, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits were dismissed with prejudice. The named defendants included various federal and state judges, municipalities, and state and county officials; the clerk was directed to close the cases and return later submissions without filing them.
What happened
Bonilla v. Court Clerk Supervisor involved multiple civil-rights lawsuits filed by Steven Wayne Bonilla, a state prisoner representing himself. He sued various federal judges, state judges, municipalities, and state and county officials over his conviction and the handling of his state and federal petitions.
The court ruled that Bonilla could not proceed without paying the filing fees because he had been disqualified under a federal statute and had not shown that he faced imminent danger when he filed the cases. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that later documents from Bonilla be returned without filing.
The detailed version
- Bonilla v. Court Clerk Supervisor · No. 4:20-cv-03655
- Phyllis Hamilton
- June 11, 2020
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The listed case numbers were 20-cv-02986-PJH, 20-cv-02987-PJH, 20-cv-02993-PJH, 20-cv-02996-PJH, 20-cv-03009-PJH, 20-cv-03011-PJH, 20-cv-03012-PJH, 20-cv-03561-PJH, 20-cv-03655-PJH, 20-cv-03657-PJH, and 20-cv-03658-PJH.
Bonilla sought permission to proceed without paying the filing fees. The opinion says that he was a condemned prisoner and had a pending federal petition concerning his confinement in the same court, where he had appointed counsel. It also says he was represented by counsel in state-court proceedings. In these civil-rights cases, he named various federal judges, state judges, municipalities, and other state and county officials. His complaints presented similar claims concerning his underlying conviction and the handling of his petitions by state and federal courts.
Reasons for the ruling
The court stated that Bonilla had already been disqualified from proceeding without paying under 28 U.S.C. § 1915(g). The court also found that the allegations did not show he was in imminent danger when he filed the complaints. For those reasons, he could not proceed without paying the filing fees.
The court further stated that, even if permission to proceed without paying were granted, the lawsuits would be barred under the doctrines and authorities identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis explaining which cited bar applied to which complaint.
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 after the cases were closed. Judge Phyllis J. Hamilton signed the order on June 11, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.