Bonilla v. Young

Background

Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government actors. He proceeded without a lawyer in these cases. The defendants included various federal judges, state judges, and state courts. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other state and federal cases.

Filing-fee determination

The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That provision permits a disqualified prisoner to proceed without fees only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the required fees.

Other barriers to the lawsuits

The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each rule’s application to each complaint.

Ruling and disposition

The court dismissed the cases with prejudice. The court also rejected the argument that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It noted that Bonilla named the judge as a defendant in three of the cases but made no specific allegations against her in those cases.

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