Bonilla v. Mendocino County Court
- Phyllis Hamilton
- 4:22-cv-05510
- 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 after finding no imminent danger and applying legal bars.
Steven Wayne Bonilla and the county clerk’s-office defendants named in the cases; the cases were closed and future submissions were ordered returned without filing.
What happened
In Steven Wayne Bonilla v. Sierra County Clerk’s Office, Steven Wayne Bonilla filed multiple nearly identical cases without a lawyer, naming county clerk’s offices as defendants.
Bonilla sought relief related to his conviction and to how other cases had been handled by state and federal courts. He was a state prisoner, and the court found that his filings did not show that he faced imminent danger of serious physical injury when he filed them.
The court dismissed the cases with prejudice, stating that they were barred by several legal rules even if Bonilla could proceed without paying the filing fee. Judge Phyllis J. Hamilton also ordered the clerk to close the cases, terminate pending motions, and return future filings without filing them.
The detailed version
- Bonilla v. Mendocino County Court · No. 4:22-cv-05510
- Phyllis Hamilton
- Oct. 5, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases have multiple docket numbers, including 22-cv-5504-PJH, 22-cv-5505-PJH, 22-cv-5506-PJH, and others listed in the order. The complaints presented nearly identical claims and named numerous county clerk’s offices as defendants.
Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts. The opinion also states that he is a condemned prisoner, has a pending federal petition challenging his custody, and is represented by counsel in state-court proceedings concerning that petition.
Inability to Proceed Without Paying the Filing Fee
The court addressed whether Bonilla could proceed in forma pauperis, meaning without paying the filing fee. Under the prisoner-litigation statute, 28 U.S.C. § 1915(g), a prisoner who has previously accumulated the specified qualifying dismissals may proceed without paying only if he was under imminent danger of serious physical injury when he filed the complaint.
The court stated that Bonilla had already been disqualified from proceeding without paying the filing fee unless he met that imminent-danger exception. It found that the allegations in these complaints did not show imminent danger at the time of filing.
Other Grounds for Dismissal
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 does not separately analyze which cited bar applies to which individual claim or case.
Disposition
The court dismissed the cases with prejudice. It directed 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. Because the cases were disposed of on filing-fee and other threshold grounds, the opinion did not decide whether Bonilla’s underlying claims were legally valid.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.