Bonilla v. Mono County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05604
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Imperial County Court Clerk’s Office, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and citing multiple legal bars.
Steven Wayne Bonilla and the defendants in the listed cases; the cases were dismissed with prejudice and closed.
What happened
In Bonilla v. Imperial County Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against county clerks and federal judges. He sought relief connected to his conviction and the handling of his other state and federal cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been barred from that status and had not shown that he faced an immediate serious physical danger when he filed. The court also said that, even if that fee waiver were granted, the lawsuits would be barred by several legal rules concerning challenges to convictions, pending proceedings, and court actions.
The court dismissed the listed cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Mono County Court Clerk's Office · No. 4:22-cv-05604
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, identified in the opinion as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, the federal statute that allows claims against state actors for violating federal rights. He represented himself in these cases. The caption lists Imperial County Court Clerk’s Office and other defendants, and the order covers the related case numbers listed in the caption.
The complaints asserted nearly identical claims against numerous county clerks and federal judges. According to the court, Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The opinion also noted that he had a pending federal petition concerning his conviction with appointed counsel and was represented by counsel in state court proceedings concerning that conviction.
Court’s reasoning
The court addressed Bonilla’s ability 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 prepaying the fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court stated that Bonilla had already been disqualified from proceeding under that provision and that the allegations did not show imminent danger at the time of filing.
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 did not analyze each doctrine separately or identify which bar applied to which individual complaint. The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality.
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 those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.