Bonilla v. Placer County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The complaints were nearly identical. They named various federal and state courts and government agencies and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled. The opinion states that Bonilla also had a pending federal petition challenging his imprisonment, with appointed counsel, and was represented by counsel in state proceedings challenging his imprisonment.

Filing-fee status

The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute allows such a prisoner to proceed without fees only if he was in immediate danger of serious physical injury when he filed. The court found that the complaints did not show that Bonilla was in such danger. He therefore could not proceed without paying the filing fees.

Other grounds for dismissal

The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, claims that cannot be brought in this form, and challenges to certain court actions. The court did not decide the underlying claims in Bonilla’s favor or against him on their merits.

Ruling and case closure

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 those closed cases. The court additionally stated that the repetitive and frivolous filings did not provide a basis to reasonably question the undersigned judge’s impartiality.