Bonilla v. Santa Cruz County Superior Court
- Phyllis Hamilton
- 4:22-cv-06514
- U.S. District Court · Northern District of California
- 2
In Steven Wayne Bonilla v. Madera County Court Clerk’s Office, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and independent legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases against county clerks and state superior courts were dismissed with prejudice; the cases were closed and future filings in them were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Madera County Court Clerk’s Office, Steven Wayne Bonilla, a condemned 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 court cases.
The court said Bonilla could not proceed without paying the filing fee because he had been disqualified from that status and had not shown that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said the lawsuits would be barred for other legal reasons even if his request to proceed without paying were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them.
The detailed version
- Bonilla v. Santa Cruz County Superior Court · No. 4:22-cv-06514
- Phyllis Hamilton
- Oct. 28, 2022
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion lists these case numbers: 22-cv-5602-PJH, 22-cv-6123-PJH, 22-cv-6240-PJH, 22-cv-6399-PJH, 22-cv-6400-PJH, 22-cv-6478-PJH, 22-cv-6479-PJH, 22-cv-6510-PJH, 22-cv-6514-PJH, 22-cv-6519-PJH, 22-cv-6528-PJH, 22-cv-6556-PJH, 22-cv-6557-PJH, 22-cv-6558-PJH, 22-cv-6559-PJH, 22-cv-6568-PJH, 22-cv-6569-PJH, 22-cv-6570-PJH, 22-cv-6571-PJH, 22-cv-6572-PJH, 22-cv-6574-PJH, and 22-cv-6575-PJH.
The complaints named numerous county clerks and state superior courts as defendants. The court said Bonilla presented nearly identical claims seeking relief concerning his underlying conviction or the handling of his other state and federal cases. The opinion also states that he had a pending federal petition concerning his conviction, with appointed counsel, and was represented by counsel in state proceedings concerning that conviction.
Proceeding Without Paying the Filing Fee
The court addressed Bonilla’s possible requests to proceed without paying the filing fee, a status commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court said Bonilla had previously been disqualified from that status unless he showed that he was under imminent danger of serious physical injury when he filed each complaint.
The court found that the allegations did not show imminent danger at the time of filing. It therefore concluded that Bonilla could not proceed without paying the filing fee.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain which listed legal bar applies to which complaint.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The order also directed the clerk to terminate all pending motions and close the cases. It further directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. The opinion does not decide the underlying civil-rights allegations on their merits; the dismissals rest on the filing-fee restriction and the additional legal bars identified by the court.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.