Bonilla v. Napa County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05605
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Imperial County Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice because filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return further submissions in those cases without filing them.
What happened
Steven Wayne Bonilla filed multiple nearly identical civil-rights cases against county clerks, federal judges, and others, challenging his conviction and how other courts handled his cases. In Steven Wayne Bonilla v. Imperial County Court Clerk’s Office, the court addressed all of these cases together.
The court ruled that Bonilla could not proceed without paying the filing fee because he had previously been barred from doing so unless he faced an immediate serious physical danger, which his complaints did not show. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also ordered the clerk to end all pending motions, close the cases, and return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Napa County Court Clerk's Office · No. 4:22-cv-05605
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, described in the opinion as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. Section 1983 is a federal law that allows a person to seek relief for certain violations of federal rights by state actors. The cases named numerous county clerks and federal judges as defendants.
The complaints were nearly identical. Bonilla sought relief related to his underlying conviction and to the way state and federal courts had handled his other cases. The opinion also states that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Ruling
The court determined that Bonilla was barred from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
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 did not separately explain which cited bar applied to which case or claim. The court therefore dismissed the cases with prejudice.
The court rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. Judge Phyllis J. Hamilton directed the clerk to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.