Bonilla v. Butte County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05618
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Imperial County Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not qualify for fee-free filing and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order terminated pending motions, closed the cases, and directed the clerk to return later submissions in those closed cases without filing them.
What happened
In Bonilla v. Imperial County Court Clerk’s Office, Steven Wayne Bonilla, a condemned 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 his other state and federal court cases.
The court said Bonilla was barred from filing without paying the required fees unless he showed that he faced imminent danger of serious physical injury when he filed. The complaints did not make that showing. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by legal rules identified in the order, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Butte County Court Clerk's Office · No. 4:22-cv-05618
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The cases involved nearly identical claims against numerous county clerks and federal judges. The complaints sought relief concerning Bonilla’s underlying conviction and the way state and federal courts handled his other cases.
The order also noted that Bonilla had a pending federal petition challenging his detention or conviction in the same court, with appointed counsel, and that he was represented by counsel in state-court proceedings concerning the same general subject.
Filing-Fee Restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show imminent danger at the relevant time. Bonilla therefore could not proceed without paying the filing fee in these cases.
Other Bars 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 the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each rule as applied to each individual case.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Classification Basis
This is a procedural order because the court disposed of the cases based on the prisoner filing-fee restriction and other threshold legal bars, rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.