Bonilla v. Trinity County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05529
- U.S. District Court · Northern District of California
- 2
Bonilla v. Sierra County Clerk’s Office: Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple lawsuits against county clerk’s offices were dismissed with prejudice, and the cases were closed. The order also directed the clerk to return without filing further documents submitted in those closed cases.
What happened
In Bonilla v. Sierra County Clerk’s Office, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer 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 had previously been barred from proceeding without paying the filing fee unless he showed an imminent danger of serious physical injury. The complaints did not show that he faced such danger when he filed them. The court also said that, even if he could proceed without paying, the lawsuits would be barred under several legal doctrines and earlier decisions.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton signed the order.
The detailed version
- Bonilla v. Trinity County Court Clerk's Office · No. 4:22-cv-05529
- 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 cases named numerous county clerk’s offices as defendants and presented nearly identical claims. The complaints sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his other cases. The order also noted that he had a pending federal petition challenging his confinement and was represented by counsel in state court proceedings challenging his confinement.
Proceeding Without Paying the Filing Fee
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. Bonilla therefore could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court further stated that, even if an application to proceed without paying the filing fee 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 explaining which cited bar applied to which lawsuit.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.