Bonilla v. Mendocino County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal judges, state judges, municipalities, and other municipal and court officials. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his petitions and other cases in state and federal court.

The opinion also notes that Bonilla had a pending federal petition challenging his confinement with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and barriers to the lawsuits

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

The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several authorities. These included rules limiting civil-rights challenges to criminal convictions, rules requiring federal courts to avoid interfering with certain ongoing state proceedings, and authorities concerning challenges to federal court actions.

Disposition

The court dismissed the cases with prejudice. It also concluded that there was no basis in these cases to question the undersigned judge’s impartiality. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.