Bonilla v. United States
- Phyllis Hamilton
- 4:22-cv-01118
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sonoma County Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla did not meet the imminent-danger exception.
Steven Wayne Bonilla’s multiple related 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 Steven Wayne Bonilla v. Sonoma County Clerk’s Office, et al., Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer. He sued counties, state courts, and clerk’s offices over his conviction and the handling of his other court cases.
The court said Bonilla had previously been barred from proceeding without paying the required filing fees unless he showed an imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying the fees, the lawsuits would be barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts’ cases.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. United States · No. 4:22-cv-01118
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, described in the order as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order 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 complaints presented nearly identical claims against several counties, state courts, and clerk’s offices. According to the order, Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. The order also noted that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status and legal barriers
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has previously accumulated qualifying dismissals generally cannot proceed without paying those fees unless he was in imminent danger of serious physical injury when he filed the complaint. The court said Bonilla had already been disqualified from proceeding under that exception unless he could show imminent danger.
The court found that the allegations did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the required fees. The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in 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 those rules.
Disposition
The court dismissed the cases with prejudice. It ordered 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.
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.