Bonilla v. Amador County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05619
- U.S. District Court · Northern District of California
- 3
Bonilla v. Imperial County Court Clerk’s Office: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla, who filed the cases, and the county clerks and federal judges named as defendants in them. The order also directs the clerk’s office to terminate pending motions, close the cases, and return later documents without filing them.
What happened
In Bonilla v. Imperial County Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He challenged his conviction or the way other state and federal court cases were handled, naming county clerks and federal judges as defendants.
The court said Bonilla could not proceed without paying filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said the lawsuits would be barred even if he could proceed without paying, citing several legal rules and prior decisions. It dismissed the cases with prejudice.
The clerk was ordered to end all pending motions and close the cases, and to return any further documents Bonilla submitted in those closed cases without filing them. Judge Phyllis Hamilton also concluded that her impartiality could not reasonably be questioned because of Bonilla’s repetitive and frivolous filings.
The detailed version
- Bonilla v. Amador County Court Clerk's Office · No. 4:22-cv-05619
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, described in the opinion as a state prisoner and condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. He represented himself in these cases. The complaints were nearly identical and named numerous county clerks and federal judges. They sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal court cases.
The opinion also states that Bonilla had a pending federal petition challenging his confinement in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings involving a similar petition.
Ruling
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has previously brought qualifying unsuccessful cases generally may not proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such imminent danger. It therefore held that he could not proceed without paying the filing fee.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules and decisions cited in the order, including rules concerning challenges to convictions, interference with ongoing state proceedings, and attacks on federal court proceedings. The court dismissed the cases with prejudice.
The court also stated that the repetitive and frivolous nature of Bonilla’s filings did not create a reasonable basis to question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.
Disposition
The listed cases were dismissed with prejudice. The order did not decide the underlying validity of Bonilla’s conviction or the merits of his allegations against the defendants; it disposed of the cases based on filing-fee restrictions and other legal bars.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.