Bonilla v. Santa Clara County Clerk's Office
- Phyllis Hamilton
- 4:22-cv-01023
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sonoma County Clerk’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights lawsuits against the counties, state courts, and clerk’s offices named in the complaints were dismissed with prejudice.
What happened
In Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla filed several nearly identical civil-rights cases without a lawyer. He sued counties, state courts, and clerk’s offices over his conviction and how other cases were handled.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced imminent danger of serious physical injury when he filed. The complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and prior decisions.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also ordered the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Santa Clara County Clerk's Office · No. 4:22-cv-01023
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named several counties, state courts, and clerk’s offices as defendants. The opinion says Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The opinion also notes that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state court proceedings. Those related proceedings were cited in the opinion but were not the matters decided by this order.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That law 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 the allegations in these complaints did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying the fees were granted, the lawsuits would be barred under the rules or decisions discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those grounds.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton entered the order on March 14, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.