Bonilla v. Mendocino County Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05968
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Imperial County Court Clerk’s Office, Judge Hamilton dismissed the related cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
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 later submissions in those cases without filing them.
What happened
Steven Wayne Bonilla, a 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 had previously been barred from filing without paying the filing fee unless he faced an immediate serious physical danger, and his complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by legal rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
The court dismissed all the cases with prejudice, terminated the pending motions, and closed the cases. It also said the judge’s impartiality could not reasonably be questioned and ordered the clerk to return future documents submitted in the closed cases without filing them. Judge Phyllis J. Hamilton signed the order.
The detailed version
- Bonilla v. Mendocino County Clerk's Office · No. 4:22-cv-05968
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases presented nearly identical claims against numerous county clerks and federal judges. The complaints sought relief concerning Bonilla’s underlying conviction and the way other state and federal cases had been handled.
The order lists multiple related case numbers, including 22-cv-5562-PJH, 22-cv-5595-PJH through 22-cv-5600-PJH, 22-cv-5603-PJH through 22-cv-5608-PJH, 22-cv-5610-PJH through 22-cv-5621-PJH, 22-cv-5818-PJH, 22-cv-5819-PJH, 22-cv-5968-PJH, and 22-cv-6056-PJH.
Proceeding Without Paying the Filing Fee
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless 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. As a result, Bonilla could not proceed without paying the filing fee.
Additional Barriers to the Lawsuits
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 discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each rule’s application to each complaint.
The court also addressed judicial impartiality. It stated that the cases were not matters in which the undersigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The court cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any additional 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.