Bonilla v. Scanlon

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He also sought permission to proceed without paying the filing fees. The complaints named various federal judges, state judges, municipalities, and other state and county officials as defendants.

The court stated that Bonilla presented very similar claims in the cases. The claims concerned his underlying conviction and the handling of his various petitions challenging his custody in state and federal courts. The order also noted that Bonilla had appointed counsel in a separate federal petition and was represented by counsel in state proceedings.

Analysis

The court held that Bonilla had already been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That provision restricts a prisoner’s ability to proceed without paying fees after qualifying prior litigation history. The court also found that the complaints did not show Bonilla was in immediate danger when he filed them, so he could not use the statutory exception to that restriction.

The court further stated that, even if Bonilla’s requests to proceed without paying fees had been granted, the lawsuits would be barred under the legal rules identified in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate merits analysis of each complaint or claim.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted after the cases were closed. The order was signed by United States District Judge Phyllis J. Hamilton.