Bonilla v. Yolo County Court Clerk's Office
- Phyllis Hamilton
- 4:22-cv-05610
- 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 Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The named county clerks and federal judges were defendants, and the clerk was directed to close the cases and return future submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against county clerks and federal judges. He sought relief concerning his conviction and the handling of his other state and federal cases.
The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced imminent danger of serious physical injury when he filed. The court also stated that the lawsuits would be barred even if his applications to proceed without fees were granted, and it dismissed the cases with prejudice.
Judge Phyllis J. Hamilton also declined to treat the repetitive filings as a reason to question her impartiality. The clerk was ordered to terminate pending motions, close the cases, and return future filings in them without filing them.
The detailed version
- Bonilla v. Yolo County Court Clerk's Office · No. 4:22-cv-05610
- Phyllis Hamilton
- Oct. 18, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. “Pro se” means he filed without a lawyer. The complaints were nearly identical and named numerous county clerks and federal judges as defendants. Bonilla sought relief concerning his underlying conviction and the way other state and federal court cases had been handled.
The order also noted that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his detention.
Rulings
The court held that Bonilla was disqualified from proceeding in forma pauperis—meaning without paying the filing fee—under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed his 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 fees were granted, the lawsuits would be barred under the authorities it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.
Other Orders and Disposition
The court stated that the repetitive and allegedly frivolous nature of the filings did not provide a basis to reasonably question Judge Hamilton’s impartiality. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Result
The multiple cases were dismissed with prejudice, and the cases were closed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.