Bonilla v. Kings County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05599
- 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 after finding fee-free filing unavailable and claims barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The cases were closed, pending motions were terminated, and the clerk was directed to return future documents submitted in those cases without filing them.
What happened
In Steven Wayne Bonilla v. Imperial County Court Clerk’s Office et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against county clerks and federal judges. He challenged his conviction and how other state and federal court cases were handled.
The court said Bonilla was barred from filing without paying fees unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said the lawsuits would be barred even if he could proceed without paying fees.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in those cases without filing them.
The detailed version
- Bonilla v. Kings County Court Clerk's Office · No. 4:22-cv-05599
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. He was representing himself in these cases. The complaints were nearly identical and named numerous county clerks and federal judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the way his other state and federal court cases had been handled.
The opinion also states that Bonilla is a condemned prisoner with a pending federal petition concerning his confinement in the same court, where he has appointed counsel. It states that he is represented by counsel in related state proceedings.
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 rule allows an exception only when a prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such a danger. Therefore, Bonilla could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines and decisions, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those barriers.
Ruling
The court dismissed the cases with prejudice. It also rejected the suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings, stating that a judge generally has a duty to decide assigned cases absent legitimate grounds for recusal.
The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order on October 18, 2022.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.