Bonilla v. Marin County Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05512
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed the related civil-rights cases with prejudice after finding no imminent danger and identifying multiple legal bars.
Steven Wayne Bonilla and the related cases he filed; the defendants were identified as numerous county clerk’s offices. The order also directed the clerk to close the cases and reject further filings in them.
What happened
Steven Wayne Bonilla filed multiple nearly identical cases against county clerk’s offices, claiming harm related to his conviction and the handling of his other cases. He is a prisoner sentenced to death and filed the cases without a lawyer.
Bonilla could not proceed without paying filing fees because he had previously been barred from that status unless he showed that he faced an immediate danger of serious physical injury. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying fees, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Marin County Clerk's Office · No. 4:22-cv-05512
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, described as a state prisoner sentenced to death, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases were assigned a series of docket 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, 22-cv-5561-PJH, and other related cases listed in the caption.
The complaints presented nearly identical claims and named numerous county clerk’s offices as defendants. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases. The opinion also notes that he had a pending federal challenge to his custody and was represented by counsel in state-court proceedings challenging his custody.
Reasons for dismissal
Bonilla was disqualified from proceeding without paying the filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show that he faced such danger.
The court further held that, even if Bonilla’s requests to proceed without paying fees were granted, the lawsuits would be barred by several legal doctrines. It cited Heck v. Humphrey, which generally restricts civil-rights suits that would undermine a conviction; Younger v. Harris, concerning federal interference with certain ongoing state proceedings; and additional authorities cited as Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The order did not decide the underlying validity of Bonilla’s conviction or his claims about how other courts handled his cases; it disposed of the lawsuits based on the filing-fee restriction and the cited legal bars.
Classification
This is a procedural order because the court dismissed the cases on threshold and other legal-bar grounds without deciding the underlying civil-rights claims on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.