Bonilla v. Shasta County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05506
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed multiple cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases against county clerk’s offices were dismissed with prejudice; the order also directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Bonilla v. Sierra County Clerk’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against county clerk’s offices. He sought relief related to his conviction and the handling of other cases by state and federal courts.
The court said Bonilla could not proceed without paying the filing fees because he had been disqualified from proceeding without paying unless he showed an imminent danger of serious physical injury. The court found that his complaints did not show such danger. It also said the lawsuits would be barred by several legal rules even if his applications to proceed without paying were granted.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Shasta County Court Clerk's Office · No. 4:22-cv-05506
- 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 and presented nearly identical claims. Bonilla sought relief concerning his underlying conviction or the way state and federal courts had handled his other cases. The opinion also states that he had a pending federal habeas case and was represented by counsel in state habeas proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing. Therefore, Bonilla could not proceed without paying the filing fees.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying 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 did not provide a separate claim-by-claim analysis of those rules.
Disposition
The court dismissed the cases with prejudice. It ordered 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.