Bonilla v. San Francisco County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05509
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not use the fee-waiver rule and his claims were barred.
Steven Wayne Bonilla’s multiple self-represented civil-rights cases against county clerk’s offices were dismissed with prejudice, and the court directed the clerk to close them and return future submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against county clerk’s offices. He challenged his conviction or the way state and federal courts handled his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that fee-waiver process and his complaints did not show that he faced an immediate risk of serious physical injury when he filed them.
In Bonilla v. Sierra County Clerk’s Office, Judge Phyllis J. Hamilton dismissed the cases with prejudice, stating that the lawsuits would also be barred under several legal doctrines even if Bonilla had been allowed to proceed without paying. The clerk was ordered to close the cases and return future filings without filing them.
The detailed version
- Bonilla v. San Francisco County Court Clerk's Office · No. 4:22-cv-05509
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The caption lists numerous related case numbers, including 22-cv-5504-PJH through 22-cv-5533-PJH and 22-cv-5561-PJH. The complaints named numerous county clerk’s offices as defendants and presented nearly identical claims.
The opinion says Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. It also says he had a pending federal case challenging his conviction and was represented by counsel in state proceedings concerning that challenge.
Fee-waiver eligibility
The court addressed Bonilla’s possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may 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 stated that Bonilla had previously been disqualified and that these complaints did not show such imminent danger.
Other grounds for dismissal
The court further stated that, even if Bonilla had been allowed to proceed without paying the filing fee, 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 analysis explaining how each doctrine applied to each case.
Ruling
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases.
Because the court disposed of the cases based on fee-waiver eligibility and other threshold legal bars rather than deciding whether Bonilla’s underlying claims were correct, this was a procedural ruling.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.