Bonilla v. Tehama County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05526
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not file without fees and the lawsuits were barred.
Steven Wayne Bonilla’s multiple related civil-rights cases were dismissed with prejudice, affecting his claims against the county clerk’s offices and other named defendants.
What happened
In Bonilla v. Sierra County Clerk’s Office, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against county clerk’s offices. He challenged his conviction and the handling of his other cases by state and federal courts.
The court said Bonilla was barred from filing without paying fees unless his complaints showed that he faced an immediate danger of serious physical injury. The court found that they did not. It also said that, even if he could proceed without paying fees, the lawsuits were barred by several legal rules and prior decisions.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton ordered the clerk to return future documents submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Tehama County Court Clerk's Office · No. 4:22-cv-05526
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal law allowing certain civil-rights claims against state actors. The order concerns 22 related case numbers, including 22-cv-5504-PJH, 22-cv-5505-PJH, 22-cv-5506-PJH, 22-cv-5508-PJH, 22-cv-5509-PJH, 22-cv-5510-PJH, 22-cv-5511-PJH, 22-cv-5512-PJH, 22-cv-5513-PJH, 22-cv-5514-PJH, 22-cv-5517-PJH, 22-cv-5518-PJH, 22-cv-5519-PJH, 22-cv-5520-PJH, 22-cv-5526-PJH, 22-cv-5528-PJH, 22-cv-5529-PJH, 22-cv-5530-PJH, 22-cv-5531-PJH, 22-cv-5532-PJH, 22-cv-5533-PJH, and 22-cv-5561-PJH. The caption identifies Sierra County Clerk’s Office and other defendants.
The complaints were nearly identical. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases. The order also noted that he had a pending federal petition challenging his detention and was represented by counsel in state-court proceedings concerning such a petition.
Reasons for dismissal
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 prisoner with that disqualification to proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.
The court added that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would still be barred under the rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
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.