Bonilla v. Fresno County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05621
- U.S. District Court · Northern District of California
- 3
Bonilla v. Imperial County Court Clerk’s Office: Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without paying and the claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also directed the clerk to terminate pending motions, close the cases, and return future documents submitted in those closed cases without filing them.
What happened
In Bonilla v. Imperial County Court Clerk’s Office, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against county clerks and federal judges. He challenged his conviction and the handling of his other court cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fees unless he showed an immediate danger of serious physical injury. The complaints did not show that danger. The court also said the lawsuits would be barred under several legal rules even if he were allowed to proceed without paying.
Judge Phyllis Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Fresno County Court Clerk's Office · No. 4:22-cv-05621
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The cases named numerous county clerks and federal judges as defendants. The complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal court cases had been handled.
The opinion states that Bonilla had a pending federal petition challenging his detention in the same court, with appointed counsel, and was represented by counsel in state-court proceedings.
Filing-fee restriction
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified from proceeding without paying under that rule.
The court found that the allegations did not show an immediate danger of serious physical injury at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other bars to the lawsuits
The court further stated that, even if an application to proceed without paying had been granted, the lawsuits would be barred under the rules 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 provide a separate claim-by-claim explanation of which cited rule applied to which allegation.
Ruling and case management
The court dismissed the cases with prejudice. It also concluded that the repetitive and frivolous nature of the filings did not provide a reason to question Judge Hamilton’s impartiality or require her recusal. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
The order was signed by United States District Judge Phyllis J. Hamilton on October 18, 2022.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.