Bonilla
- Phyllis Hamilton
- 4:22-cv-01515
- U.S. District Court · Northern District of California
- 2
Bonilla v. Sonoma County Clerk’s Office: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without paying fees and faced legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice and closed. The defendants named collectively in the opinion included several counties, state courts, and clerk’s offices; the opinion does not identify each defendant separately.
What happened
In Steven Wayne Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases. He sued counties, state courts, and clerk’s offices over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger. It also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that additional documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla · No. 4:22-cv-01515
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified in the opinion as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute used to sue for certain violations of federal rights by state actors. The complaints were nearly identical. Bonilla named several counties, state courts, and clerk’s offices as defendants and sought relief concerning his underlying conviction and the handling of his other cases.
The opinion also states that Bonilla had a pending federal petition concerning his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings concerning that petition. The opinion does not separately describe the allegations or requested relief in each of the multiple cases.
Court’s Analysis
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the specified prior dismissals generally may not proceed without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified from proceeding without paying fees under that provision unless he met the imminent-danger exception.
The court found that the allegations did not show that Bonilla was in imminent danger at the time he filed the complaints. The court therefore stated that he could not proceed without paying the filing fees. The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules or decisions identified as 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 barriers.
Disposition
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. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The opinion does not state that any of the cases were remanded or that any claim was allowed to proceed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.