Bonilla v. Ralphs

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain civil-rights claims against state actors. The complaints named various federal judges, state judges, and state courts. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.

The order also states that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel and was represented by counsel in state-court proceedings. The court noted that Bonilla had an extensive history of filing similar cases.

Fee-waiver ruling

To the extent Bonilla sought permission to proceed without paying filing fees, the court held that he was disqualified under 28 U.S.C. § 1915(g). That statute generally bars a prisoner with qualifying prior cases from proceeding without fees unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such imminent danger.

Other grounds for dismissal

The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide separate claim-by-claim analyses of those grounds.

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 additional documents Bonilla submitted in those closed cases. The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. Judge Phyllis J. Hamilton signed the order.