Bonilla v. San Francisco County Clerk's Office
- Phyllis Hamilton
- 4:22-cv-01027
- U.S. District Court · Northern District of California
- 2
Bonilla v. Sonoma County Clerk’s Office: Judge Hamilton dismissed multiple lawsuits with prejudice after finding no imminent danger and applying legal bars.
Steven Wayne Bonilla and the defendants in the multiple listed cases, including counties, state courts, and clerk’s offices.
What happened
In Steven Wayne Bonilla v. Sonoma County Clerk’s Office, a state prisoner filed multiple nearly identical civil-rights lawsuits without a lawyer against counties, state courts, and clerk’s offices. He challenged his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from that status and his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said the lawsuits would be barred even if he were allowed to proceed without paying.
Judge Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. San Francisco County Clerk's Office · No. 4:22-cv-01027
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The listed cases were Nos. 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. He named several counties, state courts, and clerk’s offices as defendants. The court said the complaints presented nearly identical claims concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The opinion also noted that Bonilla had a pending federal petition challenging his imprisonment, Case No. 08-0471 YGR, with appointed counsel, and was represented by counsel in state-court proceedings, Case No. 20-2986 PJH. Those matters were not the subject of the ruling summarized here.
Reasoning
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 was in imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not make that showing.
The court further stated that, even if an application to proceed without paying 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 provide a separate claim-by-claim analysis explaining which cited bar applied to which lawsuit.
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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.