Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:22-cv-06400
- 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 filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla’s multiple civil-rights cases against the named county clerks and state superior courts were dismissed with prejudice; the order also terminated pending motions and closed those cases.
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 lawsuits against county clerks and state superior courts. He challenged his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been barred from that status and had not shown an immediate risk of serious physical injury when he filed. The court also said the lawsuits would be barred by several legal doctrines even if he could proceed without paying.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return future filings in them without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:22-cv-06400
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state actors. He represented himself in these cases. The complaints were nearly identical and named numerous county clerks and state superior courts as defendants. The opinion says Bonilla sought relief concerning his underlying conviction or the way his other state and federal court cases had been handled.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same district court with appointed counsel and was represented by counsel in state-court proceedings concerning his custody.
Filing-fee status
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That rule permits a disqualified prisoner to proceed without paying only when the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed.
The court found that the allegations did not show such danger at the relevant time. It therefore held that Bonilla could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines. It cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine’s application to each individual case.
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 those closed cases.
Judge Phyllis J. Hamilton signed the order on October 28, 2022. This is a procedural order because the court disposed of the cases based on filing-fee restrictions and threshold legal bars 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.