Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:22-cv-06572
- U.S. District Court · Northern District of California
- 2
Bonilla v. Madera County Court Clerk’s Office: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s multiple § 1983 lawsuits against county clerks and state superior courts were dismissed with prejudice. The court also directed the clerk to close the cases and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Madera County Court Clerk’s Office et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against county clerks and state superior courts. His complaints sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla had previously been barred from proceeding without paying the filing fees unless he showed that he faced an immediate risk of serious physical injury. The court found that his complaints did not show such a risk. It also said the lawsuits would be barred by rules protecting criminal convictions and ongoing state proceedings, and by rules limiting challenges to how other courts handled cases.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:22-cv-06572
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints named numerous county clerks and state superior courts as defendants. The court said the complaints presented nearly identical claims and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.
The opinion also noted that Bonilla had a pending federal petition challenging his imprisonment in the same district court, with appointed counsel, and was represented by counsel in state-court proceedings concerning that petition. Those proceedings were not the subject of the court’s ruling here.
Reasons for dismissal
The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had already been disqualified from proceeding without paying under that provision, and it found that these complaints did not show imminent danger.
The court further stated that, even if Bonilla had been allowed to proceed without paying, the lawsuits would be barred under several legal doctrines. It cited Heck v. Humphrey, which limits civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court, which the court cited as additional barriers to the claims presented.
Disposition
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.