Bonilla v. White

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named various state courts as defendants and sought relief concerning Bonilla’s underlying conviction and the way state and federal courts handled his habeas petitions and other cases. The order also noted that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings.

Filing-fee status

The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). He could proceed under that statute only if he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not make that showing.

Other grounds cited

The court further stated that, even if Bonilla’s request to proceed without paying the filing fee were granted, 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 order did not separately explain how each cited doctrine applied to each case.

Ruling and case status

The court dismissed the cases with prejudice. It also concluded that the repetitive and allegedly frivolous filings did not provide a basis to reasonably question the undersigned judge’s impartiality. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.