Bonilla v. Los Angeles County Court Clerks Office
- Phyllis Hamilton
- 4:22-cv-05532
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, preventing those cases from proceeding. The county clerk’s offices named as defendants were affected by the closures, and any future documents Bonilla submitted in the closed cases were to be returned without filing.
What happened
Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against county clerk’s offices under a federal civil-rights law. He sought relief concerning his conviction and the handling of other cases by state and federal courts.
Bonilla was a state prisoner and had been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury. The court found that his complaints did not show such a risk. It also said that, even if he could proceed without paying, the lawsuits would be barred by several legal doctrines.
The court dismissed the cases with prejudice, terminated 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. Los Angeles County Court Clerks Office · No. 4:22-cv-05532
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, identified in the opinion as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical and named numerous county clerk’s offices as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts. The opinion also states that he was a condemned prisoner, had a pending federal petition challenging his custody, and was represented by counsel in state-court proceedings concerning that petition.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such a danger. Accordingly, he could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if Bonilla’s application to proceed without paying the fee were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine’s application to each case.
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. 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.