Bonilla v. Hamilton

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various state courts as defendants. The opinion says Bonilla sought relief concerning his underlying conviction and the handling of his other petitions and cases in state and federal courts. The opinion also notes that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.

Proceeding Without Paying Filing Fees

The court addressed Bonilla’s requests, or possible requests, to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla had already been disqualified from proceeding this way unless 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.

Other Bars Cited by the Court

The court further stated that, even if it granted permission to proceed without paying the filing fees, 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 opinion does not separately explain how each cited doctrine applied to each individual case.

Ruling and Disposition

The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submitted in those closed cases. The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question Judge Phyllis J. Hamilton’s impartiality.