Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:22-cv-06240
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Madera County Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and citing other legal bars.
Steven Wayne Bonilla and the defendants named in his 22 related cases, including county clerks and state superior courts.
What happened
In Steven Wayne Bonilla v. Madera County Court Clerk’s Office et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases. He sued county clerks and state superior courts and sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla could not waive the filing fees because he had previously been disqualified from doing so unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he could waive the fees, the lawsuits were barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:22-cv-06240
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed 22 related complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The complaints were filed without a lawyer and named numerous county clerks and state superior courts as defendants. The court said the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal courts.
Filing-fee status
Bonilla sought, or potentially sought, permission to proceed without paying the filing fee. The court referred to this as proceeding in forma pauperis, or IFP. It stated that Bonilla had previously been disqualified from proceeding IFP under 28 U.S.C. § 1915(g), unless he was under imminent danger of serious physical injury when he filed the complaint.
The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed IFP in these cases.
Other legal bars
The court further stated that, even if an IFP application were granted, the lawsuits would be barred under the 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 conduct a separate merits analysis of Bonilla’s underlying claims.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.