Bonilla v. San Mateo County Clerks Office
- Phyllis Hamilton
- 4:22-cv-01025
- U.S. District Court · Northern District of California
- 2
Bonilla v. Sonoma County Clerk’s Office was dismissed with prejudice because Judge Hamilton found no imminent danger and identified additional legal barriers.
Steven Wayne Bonilla’s multiple § 1983 civil-rights cases, including the defendants named in those cases and any further filings submitted in them.
What happened
In Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla filed multiple nearly identical civil-rights cases without a lawyer. He sued counties, state courts, and clerks’ offices over his conviction and how other cases were handled.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from that status unless he showed an immediate danger of serious physical injury. The complaints did not show such danger. The court also said the lawsuits would be barred by several legal rules even if his request to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return further documents submitted in them without filing them.
The detailed version
- Bonilla v. San Mateo County Clerks Office · No. 4:22-cv-01025
- Phyllis Hamilton
- Mar. 14, 2022
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 caption lists these related case 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 opinion says the complaints presented nearly identical claims against several counties, state courts, and clerks’ offices. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases. The opinion also notes that he had a pending federal petition concerning his conviction with appointed counsel and was represented by counsel in state-court proceedings concerning that conviction.
Reason for dismissal
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at that time.
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 does not separately explain which cited rule applied to which claim or case.
Ruling
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and 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.