Bonilla v. Napa County Superior Court Clerk's Office

Background

Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The opinion lists numerous related case numbers. Bonilla named various federal and state judges and other officials as defendants. The court described his claims as nearly identical and said they sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.

The opinion also states that Bonilla had a pending federal petition challenging his detention, in which he had appointed counsel, and that he was represented by counsel in state-court proceedings.

Fee-waiver restriction

To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. It therefore ruled that Bonilla could not proceed without paying the filing fees.

Other legal bars

The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, which limits civil-rights claims that would undermine a conviction; Younger v. Harris, concerning federal interference with certain ongoing proceedings; and Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court, which the court cited as additional bars to the requested relief.

Ruling

The court dismissed the cases with prejudice. It also rejected the contention that the assigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.