Bonilla v. Modoc County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05603
- U.S. District Court · Northern District of California
- 3
Bonilla v. Imperial County Clerk’s Office: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the claims were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice. The named defendants included Imperial County Court Clerk’s Office and other county clerks and federal judges; the clerk was directed to close the cases and return later submissions without filing them.
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 cases against county clerks and federal judges. He challenged his conviction and the handling of other cases.
The court said Bonilla could not proceed without paying the filing fees because he did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred under several legal doctrines, including rules involving challenges to convictions and interference with ongoing proceedings. It dismissed the cases with prejudice.
Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. She also directed the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Modoc County Court Clerk's Office · No. 4:22-cv-05603
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, the federal law that allows certain claims against state actors for violating federal rights. He represented himself in these cases. The complaints were nearly identical and named numerous county clerks and federal judges as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.
The opinion also states that Bonilla is a condemned prisoner with a pending federal petition challenging his conviction in the same court, where he has appointed counsel. It further states that he is represented by counsel in state court proceedings involving such a challenge.
Filing-fee restriction
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified under this provision.
The court concluded that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without paying the filing fee.
Other grounds identified by the court
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 explain how each cited doctrine applied to each individual case.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk 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 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.