Bonilla v. Clerks Office Staff
- Phyllis Hamilton
- 4:22-cv-01545
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sonoma County Clerk’s Office, Judge Hamilton denied pauper status and dismissed multiple civil-rights cases with prejudice because no imminent danger was shown and legal bars applied.
Steven Wayne Bonilla, who filed the complaints without a lawyer, and the counties, state courts, and clerk’s offices he named as defendants.
What happened
In Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla filed multiple similar civil-rights lawsuits without a lawyer against counties, state courts, and clerk’s offices. He sought relief related to his conviction and the handling of other court cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced an immediate risk of serious physical injury when he filed his complaints. The court found that his allegations did not show that risk. It also said the lawsuits would be barred under several legal doctrines even if he were allowed to proceed without paying.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The order was issued by Judge Phyllis J. Hamilton.
The detailed version
- Bonilla v. Clerks Office Staff · No. 4:22-cv-01545
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He named several counties, state courts, and clerk’s offices as defendants. The opinion says that he sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The opinion also notes that he had a pending federal petition with appointed counsel and was represented by counsel in state court proceedings.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations in these cases did not show such danger. As a result, Bonilla could not proceed without paying the filing fee.
Other Grounds Cited 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 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 opinion does not provide a separate claim-by-claim analysis of those rules.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.