Bonilla v. Inyo County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05561
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Sierra County Clerk’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because IFP was barred and the claims faced other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also terminated pending motions and closed the cases.
What happened
Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights cases without a lawyer against county clerk’s offices. He sought relief concerning his conviction and how other state and federal cases were handled.
The court said Bonilla could not proceed without paying the filing fees because he had been disqualified from that status under the three-strikes rule, and his complaints did not show an immediate danger of serious physical injury when filed. The court also said the lawsuits would be barred under several legal rules even if he were allowed to proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Inyo County Court Clerk's Office · No. 4:22-cv-05561
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion lists multiple related case numbers, including 22-cv-5504-PJH, 22-cv-5505-PJH, 22-cv-5506-PJH, 22-cv-5508-PJH through 22-cv-5519-PJH as listed, and 22-cv-5520-PJH through 22-cv-5561-PJH as listed. The complaints were nearly identical and named numerous county clerk’s offices as defendants. Bonilla sought relief concerning his underlying conviction or the way other state and federal court cases had been handled.
The opinion also states that Bonilla had a pending federal petition concerning his detention and was represented by counsel in state-court proceedings concerning that petition.
Court’s reasoning
The court addressed Bonilla’s request, to the extent he sought it, to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying under that rule. It further found that the allegations did not show imminent danger at the time of filing.
The court added that, even if an application to proceed without paying were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not analyze the underlying claims on their merits.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton on October 5, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.