Bonilla v. San Francisco County Superior Court
- Phyllis Hamilton
- 4:22-cv-06559
- 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 after finding no imminent danger and additional legal bars.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice, the pending motions were terminated, and the cases were closed. The listed county-clerk and state-court defendants were named in those cases.
What happened
In Bonilla v. Madera County Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner without a lawyer, filed multiple nearly identical civil-rights cases. He challenged his conviction and the handling of his other cases, naming county clerks and state superior courts as defendants.
The court found that Bonilla could not proceed without prepaying filing fees because his allegations did not show that he faced an immediate risk of serious physical harm when he filed the cases. The court also said the lawsuits would be barred by other legal rules even if his fee applications were granted. It dismissed the cases with prejudice, terminated the pending motions, closed the cases, and directed the clerk to return any further documents submitted in them without filing them.
Judge Phyllis J. Hamilton issued the order on October 28, 2022.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:22-cv-06559
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers the case numbered 22-cv-5602-PJH and the other listed cases numbered 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 court said the complaints presented nearly identical claims concerning Bonilla’s underlying conviction and the handling of his cases by state and federal courts.
The order also stated that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without prepaying filing fees, under 28 U.S.C. § 1915(g). That restriction applies unless a prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger at the time of filing. It therefore held that Bonilla could not proceed without prepaying the filing fees.
Other legal bars
The court further held that, even if an application to proceed without prepaying fees 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 order did not provide separate claim-by-claim explanations for which cited rule applied to which case.
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 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.