Bonilla v. San Mateo County Court Clerk's Office

Background

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

The opinion states that Bonilla was a condemned prisoner with a pending federal case challenging his imprisonment. It also states that he was represented by counsel in state court proceedings challenging his imprisonment.

Filing-fee ruling

To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) barred him from doing so unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court relied on earlier proceedings to conclude that this restriction applied to him.

The court found that the allegations did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fees.

Other barriers and disposition

The court further stated that, even if Bonilla had been allowed to proceed without paying filing fees, 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 did not resolve the underlying civil-rights allegations on their merits.

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.

Classification

This is a procedural order because the court acted on filing-fee eligibility and other threshold legal barriers rather than deciding whether Bonilla’s underlying claims were legally valid. Judge Phyllis J. Hamilton signed the order on October 5, 2022.