Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:22-cv-06558
- 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 Bonilla could not proceed without fees and the suits were barred.
Steven Wayne Bonilla’s multiple cases were dismissed with prejudice and closed. The named county clerks and state superior courts were defendants in those cases. Pending motions were terminated, and the clerk was directed to return future documents Bonilla submitted in the closed cases without filing them.
What happened
In Bonilla v. Madera County Court Clerk’s Office, Steven Wayne Bonilla filed multiple nearly identical civil-rights lawsuits against county clerks and state superior courts. He challenged his conviction and how other cases were handled.
Bonilla is a state prisoner and had been disqualified from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed the complaints. The court found that the complaints did not show such danger.
Judge Phyllis J. Hamilton also ruled that, even if Bonilla could proceed without paying fees, the lawsuits were barred by several legal doctrines. She dismissed the cases with prejudice, terminated pending motions, closed the cases, and directed the clerk to return future filings without filing them.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:22-cv-06558
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, described as a state prisoner and condemned prisoner, 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 said the complaints presented nearly identical claims concerning Bonilla’s underlying conviction and the handling of his other cases in state and federal courts.
The opinion also stated that Bonilla had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings involving a similar petition.
Court’s decision
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals may not proceed without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show imminent danger at that time.
The court further ruled that, even if Bonilla’s applications to proceed without paying 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 opinion did not explain separately which doctrine applied to which action.
Disposition and effect
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. Because the court disposed of the matters based on the filing-fee restriction and legal bars rather than deciding the underlying claims, this is classified as a procedural order.
Judge
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.