Bonilla v. San Joaquin County Court Clerks Office
- Phyllis Hamilton
- 4:22-cv-05508
- U.S. District Court · Northern District of California
- 2
Bonilla v. Sierra County Clerk’s Office: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s multiple related civil-rights cases against county clerk’s offices were dismissed with prejudice; the order also terminated pending motions and closed the cases.
What happened
Bonilla v. Sierra County Clerk’s Office involved multiple similar lawsuits filed by Steven Wayne Bonilla, a state prisoner representing himself. He sued county clerk’s offices under a federal civil-rights law and sought relief related to his conviction and the handling of other cases.
The court said Bonilla had previously lost the ability to proceed without paying filing fees unless he showed an immediate serious physical danger when he filed. The court found that his complaints did not show such danger. It also said the lawsuits would be barred even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any additional documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. San Joaquin County Court Clerks Office · No. 4:22-cv-05508
- Phyllis Hamilton
- 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 opinion lists numerous related case numbers. The complaints were nearly identical, named various county clerk’s offices as defendants, and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases.
Filing-fee status
The court addressed Bonilla’s attempt to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had already been disqualified from proceeding without paying under that provision. It found that the allegations in these complaints did not show imminent danger at the time of filing.
Other grounds cited by the court
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under the legal rules and cases it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not resolve the underlying claims in Bonilla’s favor or the defendants’ favor.
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 further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.