Bonilla v. Sonoma County Clerk's Office
- Phyllis Hamilton
- 4:22-cv-01014
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sonoma County Clerk’s Office, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice after finding he could not proceed without paying filing fees.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
What happened
Bonilla v. Sonoma County Clerk’s Office involved multiple nearly identical complaints by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. The complaints were brought under a federal civil-rights law and challenged his conviction or the handling of his other cases by state and federal courts.
The court found that Bonilla could not proceed without paying filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits would be barred by legal rules concerning challenges to convictions, ongoing proceedings, and certain court actions. It dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future documents without filing them.
Judge Phyllis J. Hamilton issued and signed the order on March 14, 2022.
The detailed version
- Bonilla v. Sonoma County Clerk's Office · No. 4:22-cv-01014
- Phyllis Hamilton
- Mar. 14, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covered the following case numbers: 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.
The complaints were nearly identical. Bonilla named several counties, state courts, and clerks’ offices as defendants. The order states that he sought relief concerning his underlying conviction and the way other state and federal cases had been handled. It also notes that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state proceedings.
Court’s Analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying the fee may do so only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified under that statute and that his allegations did not show imminent danger at the relevant time. The court therefore concluded that he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying the fee 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 order did not provide a separate analysis of how each cited authority applied to each individual case.
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. The order was signed by United States District Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.