Bonilla v. Yuba County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05612
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Imperial County Court Clerk’s Office, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple § 1983 civil-rights cases were dismissed with prejudice. The order also ended pending motions, closed the cases, and directed the clerk to return future documents submitted in them 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. He sued county clerks and federal judges over his conviction and the handling of other state and federal court cases.
The court said Bonilla could not proceed without paying the filing fees because his allegations did not show imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred for other legal reasons even if his fee-waiver applications were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Yuba County Court Clerk's Office · No. 4:22-cv-05612
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 while incarcerated. The opinion identifies him as a state prisoner and says he was condemned. He represented himself in these cases, while having appointed counsel in a separate federal petition and counsel in state-court proceedings.
The complaints presented nearly identical claims against numerous county clerks and federal judges. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases. The order applied to multiple cases, including Case Nos. 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.
Court’s analysis
The court addressed Bonilla’s possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without prepayment of fees may do so only when the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified under that provision. It found that the allegations in these complaints did not show imminent danger at the relevant time.
The court further stated that, even if Bonilla’s applications to proceed without prepaying fees were granted, the lawsuits would be barred under the legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain which principle applied to which complaint.
The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It cited the rule that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Ruling
Judge Phyllis J. Hamilton dismissed the cases 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 those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.