Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:22-cv-06399
- 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 his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return future submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights cases without a lawyer against county clerks and state superior courts. He sought relief concerning his conviction and the handling of other cases in state and federal court.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed an imminent danger of serious physical injury. The complaints did not make that showing. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal doctrines concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:22-cv-06399
- 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 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 court, with appointed counsel, and was represented by counsel in state proceedings concerning that petition.
Filing-fee status
The court addressed Bonilla’s possible requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has had qualifying prior cases dismissed generally may not proceed without paying the fee 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 fees under that rule.
The court found that the allegations in these complaints did not show imminent danger at the time of filing. It therefore held that Bonilla could not proceed without paying the filing fees.
Other bars to the lawsuits
The court further stated that, even if Bonilla’s applications to proceed without fees were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; and Ninth Circuit decisions cited as Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court.
The opinion did not separately explain which doctrine applied to which complaint or claim.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed 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.