Bonilla v. Monterey County Superior Court
- Phyllis Hamilton
- 4:22-cv-06574
- 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 paying 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 lawsuits without a lawyer against county clerks and state superior courts. He sought relief related to his conviction and the handling of his other cases by state and federal courts.
The court ruled that Bonilla could not proceed without paying the filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying, his lawsuits were barred by several legal rules concerning challenges to convictions, ongoing state proceedings, and court actions.
Judge Phyllis J. Hamilton dismissed all of the cases with prejudice, terminated the pending motions, and ordered the clerk to close the cases and return future documents without filing them.
The detailed version
- Bonilla v. Monterey County Superior Court · No. 4:22-cv-06574
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla, a state prisoner described in the order as condemned, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims and named numerous county clerks and state superior courts as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The order also noted that Bonilla had a pending federal petition challenging his detention in the same district, with appointed counsel, and was represented by counsel in state court proceedings.
Court’s analysis
The court explained that Bonilla had previously been barred from proceeding without paying filing fees under the “three strikes” provision, 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed. The allegations in these complaints did not show such danger. Therefore, the court ruled that he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under rules and doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.