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N.D. Cal.Procedural orderFiled Oct. 5, 2022

Bonilla v. Siskiyou County Court

Judge
Phyllis Hamilton
Docket
4:22-cv-05505
Court
U.S. District Court · Northern District of California
Pages
2
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and additional legal barriers.

Who this affects

Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the county clerk’s offices named as defendants and directed the clerk of court to close the cases and return future filings without filing them.

What happened

In Bonilla v. Sierra County Clerk’s Office, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases against county clerk’s offices. He sought relief related to his conviction and the handling of other cases by state and federal courts.

The court found that Bonilla could not proceed without paying the filing fee because his allegations did not show imminent danger of serious physical injury when he filed. The court also stated that the lawsuits would be barred for additional legal reasons even if he were allowed to proceed without paying. It dismissed the cases with prejudice and directed the clerk to close them and return future filings without filing them.

Judge Phyllis J. Hamilton issued the order on October 5, 2022. The order terminated all pending motions and closed the listed cases.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Siskiyou County Court · No. 4:22-cv-05505
Judge
Phyllis Hamilton
Date
Oct. 5, 2022

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints presented nearly identical claims and named numerous county clerk’s offices as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.

The opinion also states that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning such a petition.

Ruling

The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That rule generally prevents a prisoner with qualifying prior dismissals from proceeding without paying 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 imminent danger at the relevant time. Therefore, he could not proceed without paying the filing fee. The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under several legal doctrines and precedents, including rules concerning challenges to criminal judgments, ongoing state proceedings, and certain claims against courts or court-related defendants.

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.

Effect

The order ended the listed cases and barred their refiling based on the court’s stated disposition of dismissal with prejudice. It did not grant relief concerning Bonilla’s conviction or his allegations about the handling of his other cases.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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