Bonilla v. Sierra County
- Phyllis Hamilton
- 4:22-cv-05504
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, affecting his claims against the listed county clerk’s offices; the cases were closed and future submissions were to be returned without filing.
What happened
Bonilla v. Sierra County Clerk’s Office involved Steven Wayne Bonilla, a state prisoner who filed multiple nearly identical civil-rights complaints without a lawyer under a federal civil-rights law. He sued numerous county clerk’s offices and sought relief concerning his conviction or the handling of his other state and federal cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from using the fee-waiver process, and his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was also ordered to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Sierra County · No. 4:22-cv-05504
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state or local actors. 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 in state and federal courts.
Fee-waiver issue
The court explained that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the required filing fees, under 28 U.S.C. § 1915(g). That restriction applies unless a prisoner shows that he was facing an imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such a danger, so Bonilla could not proceed without paying the filing fees.
Other legal bars
The court further stated that, even if Bonilla’s applications to proceed without fees were granted, the lawsuits would be barred under the rules and decisions discussed in the order, including 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 bar in detail.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.