Bonilla v. Unconstitutional Law

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The defendants included various state courts, federal judges, and court officials. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court.

The opinion states that Bonilla had a pending federal petition concerning his conviction, with appointed counsel, and was also represented by counsel in state court proceedings.

Filing-fee status and legal bars

Bonilla was subject to the filing-fee restriction in 28 U.S.C. § 1915(g). That rule prevented him from proceeding without paying the filing fee unless he showed that he faced an imminent danger of serious physical injury when he filed the complaint. The court found that these complaints did not show such a danger.

The court further stated that, even if Bonilla were permitted to proceed without paying the fees, the lawsuits would be barred under several legal doctrines and precedents, including the rule concerning challenges to convictions that have not been invalidated, the rule limiting federal interference with certain ongoing state proceedings, and other restrictions identified by the court.

Ruling

The court dismissed the cases with prejudice. It also directed the clerk to terminate all pending motions and close the cases. The clerk was directed to return, without filing, any additional documents Bonilla submitted in the closed cases.

The court additionally stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the undersigned judge’s impartiality. The opinion does not state that a separate recusal motion was granted or denied.