Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:22-cv-06557
- U.S. District Court · Northern District of California
- 2
Bonilla v. Madera County Court Clerk’s Office: Judge Hamilton dismissed the prisoner’s related civil-rights cases with prejudice because he could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple related civil-rights lawsuits were dismissed with prejudice; the clerk was ordered to close the cases and return later submissions without filing.
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 sought relief concerning his conviction and the handling of his other cases by state and federal courts.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed an imminent danger of serious physical injury. The complaints did not show that danger. The court also said that, even if he could proceed without paying, the lawsuits were barred by several legal rules and precedents, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate pending motions and close the cases, and ordered that future documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:22-cv-06557
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints named numerous county clerks and state superior courts as defendants and presented nearly identical claims. Bonilla sought relief related to his underlying conviction or to the handling of his other cases by state and federal courts.
The opinion also notes that Bonilla had a pending federal petition challenging his conviction in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings.
Reasoning
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that these allegations did not show such 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 does not separately explain which cited rule applied to which individual case or claim.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk 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.
Case-number note
The caption lists multiple related case 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.