Bonilla v. Sonoma County Court Clerks Office
- Phyllis Hamilton
- 4:22-cv-05518
- 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 receive a filing-fee waiver and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases against county clerk’s offices were dismissed with prejudice, and his pending motions and future submissions in those closed cases were affected by the order.
What happened
In Steven Wayne Bonilla v. Sierra County Clerk’s Office, Bonilla filed multiple civil-rights lawsuits without a lawyer against county clerk’s offices. The cases raised nearly identical claims about his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from receiving a fee waiver, and his complaints did not show that he faced an immediate serious physical danger when he filed them. The court also said the lawsuits would be barred under several legal rules even if a fee waiver were granted.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Sonoma County Court Clerks Office · No. 4:22-cv-05518
- 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 complaints named numerous county clerk’s offices as defendants. Bonilla presented nearly identical claims and sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.
The order addresses these related case numbers: 22-cv-5504-PJH, 22-cv-5505-PJH, 22-cv-5506-PJH, 22-cv-5508-PJH, 22-cv-5509-PJH, 22-cv-5510-PJH, 22-cv-5511-PJH, 22-cv-5512-PJH, 22-cv-5513-PJH, 22-cv-5514-PJH, 22-cv-5517-PJH, 22-cv-5518-PJH, 22-cv-5519-PJH, 22-cv-5520-PJH, 22-cv-5526-PJH, 22-cv-5528-PJH, 22-cv-5529-PJH, 22-cv-5530-PJH, 22-cv-5531-PJH, 22-cv-5532-PJH, 22-cv-5533-PJH, and 22-cv-5561-PJH.
Filing-fee waiver
A person who cannot afford filing fees may ask to proceed without paying them, commonly called proceeding in forma pauperis. The court stated that Bonilla had already been disqualified from using that procedure under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that his allegations did not show such danger. Accordingly, he could not proceed under the fee-waiver procedure.
Other grounds for dismissal
The court further stated that, even if a fee-waiver application 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 separate claim-by-claim explanations of how each cited rule applied.
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. The order was signed by United States District Judge Phyllis J. Hamilton on October 5, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.