Bonilla v. Napa County

Background

Steven Wayne Bonilla, a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The complaints named various federal judges, state judges, municipalities, and other municipal and court officials as defendants. The court said the cases presented very similar claims concerning Bonilla’s underlying conviction and the handling of his self-represented habeas petitions and other cases.

The court also noted that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody.

Ruling

The court held that Bonilla was disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaints. The court relied on prior proceedings that had disqualified him from that status and found that these complaints did not show imminent danger at the time of filing.

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 discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court dismissed the cases with prejudice. It did not decide the underlying challenges to Bonilla’s conviction or the handling of his other cases.

The court also stated that its impartiality could not reasonably be questioned. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submitted in the closed cases.

Disposition

The multiple cases were dismissed with prejudice. The order separately directed the clerk to terminate pending motions and close the cases.