Bonilla v. 4th Amendment Violation
- Phyllis Hamilton
- 4:22-cv-01512
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Sonoma County Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not show imminent danger and the claims would be barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the named counties, state courts, and clerk’s offices as defendants, and directed the clerk to close the cases and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla filed multiple civil-rights cases without a lawyer. The court described him as a state prisoner and said his cases raised nearly identical challenges involving his conviction and the handling of other cases by courts and clerk’s offices.
The court said Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status and had not shown that he faced an immediate risk of serious physical injury when he filed. The court also said the lawsuits would be barred even if he were allowed to proceed without fees.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. 4th Amendment Violation · No. 4:22-cv-01512
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion describes Bonilla as a state prisoner and a condemned prisoner. It also says he had a pending federal petition concerning his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment.
The complaints presented nearly identical claims. Bonilla named several counties, state courts, and clerk’s offices as defendants. According to the opinion, he sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
Proceeding Without Filing Fees
The court said that, to the extent Bonilla sought permission to proceed without paying filing fees, 28 U.S.C. § 1915(g) barred him from doing so because he had previously been disqualified from that status. The statute provides an exception when a prisoner is in imminent danger of serious physical injury at the time the complaint is filed.
The court found that Bonilla’s allegations did not show that he was in such danger when he filed the complaints. It therefore concluded that he could not proceed without paying filing fees.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without filing fees were granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain how each cited decision applied to each individual case.
Disposition
The court dismissed the cases with prejudice. The opinion uses that exact disposition and does not limit it to particular claims or defendants. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
The order was signed by United States District Judge Phyllis J. Hamilton on March 14, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.