Bonilla v. Humboldt County Court Clerks Office
- Phyllis Hamilton
- 4:22-cv-05513
- 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 fees and his claims were barred.
Steven Wayne Bonilla, a state prisoner representing himself, and the county clerk’s offices named as defendants in the multiple cases.
What happened
In Bonilla v. Sierra County Clerk’s Office, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against county clerks’ offices. He challenged his underlying conviction or the handling of his other cases in state and federal court.
The court said Bonilla could not proceed without paying the filing fees because he had previously been disqualified from using the fee-waiver process. His complaints also did not show that he faced an immediate danger of serious physical injury when he filed them. The court further stated that, even if he were allowed to proceed without fees, the lawsuits were barred by several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Humboldt County Court Clerks Office · No. 4:22-cv-05513
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion identifies him as a state prisoner and a condemned prisoner. The cases name numerous county clerks’ offices as defendants and present nearly identical claims. Bonilla sought relief concerning his underlying conviction or 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.
Filing-fee status
Bonilla was subject to 28 U.S.C. § 1915(g), which generally prevents a prisoner who has accumulated qualifying prior dismissals from proceeding without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court determined that the allegations did not show imminent danger. As a result, Bonilla could not proceed without paying the filing fees.
Other grounds identified by the court
The court stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain which rule applied to which case or claim.
Disposition
The court dismissed the cases with prejudice. It ordered 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.
Caption discrepancy
The supplied case name refers to the Humboldt County Court Clerks Office, but the opinion’s caption identifies the defendant as the Sierra County Clerk’s Office. This summary follows the opinion’s caption. The opinion lists multiple related case numbers; the metadata header uses 22-cv-5504-PJH as the first listed number.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.