Bonilla v. San Benito County Superior Court
- Phyllis Hamilton
- 4:22-cv-06575
- 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 citing several legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the order also directed the clerk to close those cases and reject further submissions in them.
What happened
In Bonilla v. Madera County Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases. He sued county clerks and state superior courts over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee because he had previously been disqualified from proceeding without one, and his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if he had been allowed to proceed without paying, the lawsuits would be barred by several legal rules.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also directed the clerk to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. San Benito County Superior Court · No. 4:22-cv-06575
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a condemned state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named numerous county clerks and state superior courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The order states that Bonilla had a pending federal petition challenging his custody in the same district court, where he had appointed counsel. It also states that he was represented by counsel in state-court proceedings concerning his custody.
Court’s reasoning
The court explained that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee. That provision allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed.
The court found that Bonilla’s allegations did not show such danger. It therefore held that he could not proceed without paying the filing fee. The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several legal doctrines and authorities, including rules limiting civil-rights challenges to convictions and restrictions on federal interference with ongoing state proceedings.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order. The order resolved the cases on filing-status and other threshold grounds rather than deciding the underlying allegations on their merits.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.