Bonilla v. Sutter County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The opinion describes him as a condemned prisoner who also had a pending federal petition challenging his conviction, with appointed counsel, and state-court proceedings in which he was represented by counsel.

The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.

Court’s analysis

The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fees unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The allegations did not make that showing, so he could not proceed without paying the fees.

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 cited in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court also stated that the repetitive and allegedly frivolous nature of the filings did not provide a reason to question the undersigned judge’s impartiality.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The opinion does not decide the underlying conviction-related claims on their merits; it disposes of the cases based on the filing-fee restriction and the additional legal bars identified by the court.