Bonilla v. Declaratory Judgment 4
- Phyllis Hamilton
- 4:22-cv-01513
- U.S. District Court · Northern District of California
- 2
Bonilla v. Sonoma County Clerk’s Office: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees 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 future submissions without filing them.
What happened
In Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against counties, state courts, and clerk’s offices. He challenged his conviction and how other cases had been handled.
Bonilla is a state prisoner proceeding without a lawyer in these cases. The court said he was barred from proceeding without paying filing fees unless he showed imminent danger of serious physical injury, and his complaints did not make that showing.
Judge Phyllis J. Hamilton also ruled that the lawsuits would be barred under several legal doctrines even if Bonilla could proceed without paying fees. The court dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future submissions without filing them.
The detailed version
- Bonilla v. Declaratory Judgment 4 · No. 4:22-cv-01513
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases were assigned the following numbers: 22-cv-1014-PJH, 22-cv-1023-PJH, 22-cv-1025-PJH, 22-cv-1027-PJH, 22-cv-1028-PJH, 22-cv-1118-PJH, 22-cv-1511-PJH, 22-cv-1512-PJH, 22-cv-1513-PJH, 22-cv-1514-PJH, 22-cv-1515-PJH, 22-cv-1516-PJH, 22-cv-1529-PJH, 22-cv-1530-PJH, and 22-cv-1545-PJH.
The court said the complaints presented nearly identical claims against several counties, state courts, and clerk’s offices. The requested relief concerned Bonilla’s underlying conviction or the handling of his other state and federal cases. The opinion also noted that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying the filing fee 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 doctrine or identify which specific doctrine applied to each case.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.