Bonilla v. Lassen County Court Clerk's Office

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law that allows claims for violations of constitutional rights by people acting under state authority. The complaints named numerous county clerks and federal judges. The court said the complaints presented nearly identical claims concerning Bonilla’s underlying conviction and the way his other cases had been handled by state and federal courts.

The order covered the following related cases: 22-cv-5562-PJH, 22-cv-5595-PJH, 22-cv-5596-PJH, 22-cv-5597-PJH, 22-cv-5598-PJH, 22-cv-5599-PJH, 22-cv-5600-PJH, 22-cv-5601-PJH, 22-cv-5603-PJH, 22-cv-5604-PJH, 22-cv-5605-PJH, 22-cv-5606-PJH, 22-cv-5607-PJH, 22-cv-5608-PJH, 22-cv-5610-PJH, 22-cv-5611-PJH, 22-cv-5612-PJH, 22-cv-5615-PJH, 22-cv-5618-PJH, 22-cv-5619-PJH, 22-cv-5621-PJH, 22-cv-5818-PJH, 22-cv-5819-PJH, 22-cv-5968-PJH, and 22-cv-6056-PJH.

Proceeding Without Paying Filing Fees

The court addressed Bonilla’s possible requests to proceed without paying the filing fees, commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot use that procedure 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 statute. It found that the allegations in these complaints did not show imminent danger at the time of filing. The court therefore concluded that Bonilla could not proceed without paying the filing fees.

Other Grounds for Dismissal

The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis explaining which doctrine applied to which complaint or claim.

Ruling and Case Status

The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous nature of the filings, explaining that judges generally have a duty to decide assigned cases absent legitimate grounds for recusal.

The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order on October 18, 2022.