Bonilla v. Humboldt County Superior Court
- Phyllis Hamilton
- 4:22-cv-06556
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Madera County Court Clerk’s Office, Judge Hamilton dismissed the cases with prejudice after finding no imminent danger and identifying several legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases against county clerks and state superior courts were dismissed with prejudice. The order also terminated pending motions and closed the cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases under Section 1983 against county clerks and state superior courts. He sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla did not show he faced imminent danger of serious physical injury when he filed the complaints. Because of that finding, he could not proceed without paying filing fees. The court also said that, even if it had allowed him to proceed that way, several legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, meaning the dismissals barred refiling these claims in these cases. Judge Phyllis J. Hamilton also directed the clerk to terminate pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Humboldt County Superior Court · No. 4:22-cv-06556
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints named numerous county clerks and state superior courts as defendants. The court stated that the complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The court also noted that Bonilla had a pending federal petition challenging his custody in the same district, with appointed counsel, and was represented by counsel in state-court proceedings.
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), unless he showed that he was in imminent danger of serious physical injury when he filed each complaint. The court found that the allegations did not show such imminent danger. It therefore concluded 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 had been granted, the lawsuits would be barred under the rules and decisions identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide separate analysis of each cited bar.
Disposition
The court dismissed the cases with prejudice. It directed 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 United States District Judge Phyllis J. Hamilton.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.