Bonilla v. Clay

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights law. The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.

The opinion states that Bonilla is a condemned prisoner who has a pending federal petition challenging his custody with appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning his custody.

Reasons for the Ruling

The court explained that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying filing fees, under 28 U.S.C. § 1915(g). That restriction applies unless a prisoner shows that he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.

The court further held that, even if Bonilla had been allowed to proceed without prepaying fees, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion also stated that the court’s impartiality could not reasonably be questioned merely because of the repetitive and frivolous nature of the filings.

Disposition

The court dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.

Classification

This is a procedural order because the court dismissed the cases based on the prisoner-filing-fee restriction and other threshold legal bars, without deciding whether Bonilla’s underlying civil-rights claims were legally correct.