Bonilla v. Court Clerk's Office
- Phyllis Hamilton
- 4:23-cv-00607
- U.S. District Court · Northern District of California
- 2
In Bonilla v. 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 lawsuits were dismissed with prejudice. The order also barred him from proceeding without paying filing fees in these cases and directed the clerk to close the cases and return later submissions without filing them.
What happened
In Bonilla v. Court Clerk’s Office, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights cases against courts and officials. He sought relief connected to his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed an immediate serious danger of physical injury. His complaints did not show that danger. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return later documents without filing them.
The detailed version
- Bonilla v. Court Clerk's Office · No. 4:23-cv-00607
- Phyllis Hamilton
- Feb. 22, 2023
Background
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 while representing himself. He sued various courts and officials and sought relief concerning his underlying conviction and the way state and federal courts handled his other cases. The opinion also states that he had a pending federal petition challenging his confinement with appointed counsel and was represented by counsel in state-court proceedings.
Proceeding Without Paying Filing Fees
Bonilla sought, or potentially sought, permission to proceed without paying the filing fees. The court stated that he had previously been disqualified from that status under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Therefore, he could not proceed without paying the fees.
Other Bars to the Lawsuits
The court further stated that, even if Bonilla’s application to proceed without paying fees 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 provide a separate analysis explaining which bar applied to which claim.
Ruling
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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.