Bonilla v. Maier

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that permits certain claims against government officials. The order lists numerous related case numbers. Bonilla is described as a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and with counsel in state-court proceedings. The complaints were nearly identical and named various federal and state judges and other officials. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.

Filing-fee status

The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That provision generally prevents a prisoner with the relevant filing history from proceeding without fees unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. He therefore could not proceed without paying the filing fees.

Other grounds identified by the court

The court further stated that, even if Bonilla’s applications to proceed without paying fees were granted, the lawsuits would be barred under several doctrines and precedents, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide whether Bonilla’s underlying civil-rights allegations were factually or legally correct; it dismissed the cases based on the filing-fee restriction and the stated procedural or legal bars.

Ruling

The court dismissed the cases with prejudice. It also concluded that the repetitive and frivolous filings did not provide a basis to question the impartiality of the judge assigned to the cases. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.

Practical effect stated in the order

The dismissal with prejudice ended the listed cases and barred refiling those same claims in the dismissed actions. The order also directed the clerk not to file additional documents Bonilla submitted in the closed cases.