Bonilla
- Phyllis Hamilton
- 4:22-cv-06510
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Madera County Court Clerk’s Office, Judge Hamilton dismissed with prejudice Bonilla’s multiple pro se civil-rights cases, finding no imminent danger and citing several legal bars.
Steven Wayne Bonilla’s 22 related civil-rights cases were dismissed with prejudice. The named defendants were the Madera County Court Clerk’s Office and other county clerks and state superior courts; pending motions were terminated and future filings in the closed cases were to be returned without filing.
What happened
Steven Wayne Bonilla filed multiple civil-rights cases against county clerks and state superior courts. He challenged matters involving his conviction and the handling of his other cases.
Bonilla is a state prisoner and had been barred from using the court’s fee-waiver process unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not make that showing.
The court also said that, even if Bonilla could proceed without paying fees, the lawsuits were barred by several legal rules. Judge Phyllis J. Hamilton dismissed all the cases with prejudice, terminated the pending motions, closed the cases, and directed the clerk to return any further filings in them without filing them.
The detailed version
- Bonilla · No. 4:22-cv-06510
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed 22 related complaints under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints named numerous county clerks and state superior courts as defendants. The court said the complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal courts.
The opinion also noted that Bonilla was a condemned prisoner with a pending federal petition challenging his confinement in the same court, where he had appointed counsel. It further noted that he was represented by counsel in state-court proceedings.
Court’s analysis
The court addressed Bonilla’s possible use of the federal fee-waiver process, called proceeding “in forma pauperis.” Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from using that process unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court determined that the allegations did not show imminent danger at the relevant time.
The court added that, even if a fee-waiver application were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not identify which specific rule applied to each individual 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 on October 28, 2022.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.