Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:22-cv-06568
- 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 because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants named in those cases were numerous county clerks and state superior courts.
What happened
In Bonilla v. Madera County Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against county clerks and state superior courts. He sought relief related to his conviction and the handling of other cases by state and federal courts.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury. The complaints did not show that risk. The court also said that, even if he could proceed without paying fees, the lawsuits were barred by legal rules identified in the order.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:22-cv-06568
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The cases named numerous county clerks and state superior courts 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 order identifies the cases by multiple docket numbers, including 22-cv-5602-PJH, 22-cv-6123-PJH, 22-cv-6240-PJH, 22-cv-6399-PJH, 22-cv-6400-PJH, 22-cv-6478-PJH, 22-cv-6479-PJH, 22-cv-6510-PJH, 22-cv-6514-PJH, 22-cv-6519-PJH, 22-cv-6528-PJH, 22-cv-6556-PJH, 22-cv-6557-PJH, 22-cv-6558-PJH, 22-cv-6559-PJH, 22-cv-6568-PJH, 22-cv-6569-PJH, 22-cv-6570-PJH, 22-cv-6571-PJH, 22-cv-6572-PJH, 22-cv-6574-PJH, and 22-cv-6575-PJH. The opinion also notes that Bonilla had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings.
Filing-fee restriction
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in “imminent danger of serious physical injury” when he filed the complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.
Additional barriers identified by the court
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 discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those barriers.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton.
Classification note
This is a procedural order because the court disposed of the cases based on the filing-fee restriction and other threshold legal barriers rather than deciding the underlying civil-rights claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.