Bonilla v. Imperial County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05562
- U.S. District Court · Northern District of California
- 3
In 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 his claims were barred.
Steven Wayne Bonilla and the related cases listed in the order; the defendants named in those cases were not required to litigate the complaints because the cases were dismissed with prejudice.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against county clerks and federal judges. He challenged his underlying conviction and the handling of his other cases by state and federal courts.
The court said Bonilla was barred from proceeding without paying the filing fees because he had previously been disqualified from that status and did not show that he faced an immediate serious physical danger when he filed. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing proceedings, and court decisions.
The court dismissed all of the listed cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future documents without filing them. Judge Phyllis J. Hamilton also stated that the repetitive and frivolous filings did not reasonably call her impartiality into question.
The detailed version
- Bonilla v. Imperial County Court Clerk's Office · No. 4:22-cv-05562
- 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 while representing himself. 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 state and federal courts handled his other cases.
The opinion also noted that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel and was represented by counsel in state-court proceedings concerning that conviction.
Filing-fee status and barriers to the lawsuits
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under the federal Prison Litigation Reform Act’s “three strikes” provision, 28 U.S.C. § 1915(g). That provision allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not make that showing.
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under rules and doctrines identified 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 the application of each cited doctrine to each individual case.
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 further documents Bonilla submitted in the closed cases.
The court additionally stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question Judge Hamilton’s impartiality. The opinion does not identify a separate recusal motion or state that one was formally granted or denied.
Classification basis
This is a procedural order. The court resolved the matters through filing-fee eligibility and threshold legal bars rather than deciding the merits of Bonilla’s underlying challenges to his conviction or to the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.