Bonilla v. Sutter County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05519
- U.S. District Court · Northern District of California
- 2
Judge Hamilton dismissed Bonilla v. Sierra County Clerk’s Office and related cases with prejudice after finding no imminent danger and legal bars to the lawsuits.
Steven Wayne Bonilla’s multiple nearly identical civil-rights cases against county clerk’s offices were dismissed with prejudice and closed.
What happened
In Bonilla v. Sierra County Clerk’s Office and related cases, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights lawsuits against county clerk’s offices. He sought relief concerning 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 fees because he had been disqualified from proceeding without fees unless he showed imminent danger of serious physical injury. The complaints did not show that danger. The court also stated that the lawsuits would be barred by several legal rules even if his fee request were granted.
Judge Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Sutter County Court Clerk's Office · No. 4:22-cv-05519
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases 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 way his other cases had been handled by state and federal courts.
The order covers the following 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.
Reasons for the ruling
The court addressed Bonilla’s possible request to proceed without paying filing fees, commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from using that procedure may proceed only if 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, so he could not proceed without paying the fees.
The court further stated that, even if Bonilla’s request to proceed without fees 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 opinion does not resolve the underlying claims on their merits; it relies on the filing-fee restriction and these legal bars.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and 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.