Bonilla v. Jackson

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical and named various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court. The order states that he is a condemned prisoner with a pending federal petition challenging his custody, for which he has appointed counsel, and that he is represented by counsel in state-court proceedings.

Reasons for Dismissal

The court ruled that Bonilla could not proceed without paying the filing fee under 28 U.S.C. § 1915(g). That provision disqualifies a prisoner from proceeding without the fee after qualifying prior filings unless the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger.

The court further stated that, even if Bonilla's applications to proceed without paying the fee had been granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order also noted Bonilla's extensive history of filing similar cases.

Ruling and Case Closure

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

Classification

This is a procedural order because the court resolved the cases based on filing-fee eligibility and other threshold legal bars rather than deciding the underlying civil-rights claims.