Bonilla v. Unknown
- Phyllis Hamilton
- 4:22-cv-01511
- 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 because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 lawsuits concerning his conviction and the handling of his other cases were dismissed with prejudice; the named counties, state courts, and clerk’s offices were defendants.
What happened
In Bonilla v. Sonoma County Clerk’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against counties, state courts, and clerk’s offices. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The court found that his allegations did not show that danger. It also said that, even if he had been allowed to proceed without fees, his lawsuits would be barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and ordered the clerk to return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Unknown · No. 4:22-cv-01511
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified 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 for certain claims against government actors. The order covers the listed related cases, including Case 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 through 22-cv-1516-PJH, and 22-cv-1529-PJH, 22-cv-1530-PJH, 22-cv-1545-PJH. The complaints presented nearly identical claims and named several counties, state courts, and clerk’s offices as defendants. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The order also noted that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. Those related proceedings were not the matters decided by this order.
Reasoning
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That provision generally prevents a prisoner with the relevant prior filings from proceeding without fees unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger at the relevant time.
The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the rules or doctrines identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately explain which cited bar applied to which complaint or claim.
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 on March 14, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.