Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:22-cv-06571
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Madera County Court Clerk’s Office et al., Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without paying filing fees and his lawsuits were barred.
Steven Wayne Bonilla’s 22 related civil-rights cases were dismissed with prejudice. The defendants named in those cases were county clerks and state superior courts. The clerk was also directed to close the cases, terminate pending motions, and return later submissions without filing them.
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 lawsuits against county clerks and state superior courts. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury when he filed his complaints. The court found that his allegations did not show such a danger. It also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and certain claims against courts.
The court dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that future documents Bonilla submitted in the closed cases be returned without filing. Judge Phyllis J. Hamilton signed the order on October 28, 2022.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:22-cv-06571
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases carried the following case numbers: 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. He named numerous county clerks and state superior courts as defendants. The complaints were nearly identical and sought relief related to his underlying conviction or the handling of his other cases in state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his conviction, for which he had appointed counsel, and was represented by counsel in state court proceedings. The opinion does not explain the specific claims in each complaint beyond describing them as related to his conviction and the handling of his other cases.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying may do so only if, when the complaint was filed, the prisoner was in immediate danger of serious physical injury. The court stated that Bonilla had previously been disqualified under that statute and found that these complaints did not show such an immediate danger.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately identify which bar applied to which complaint or claim.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.