Bonilla v. Humphreys

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute that permits certain civil-rights claims against state actors. The complaints named various state courts and state officials. They presented very similar claims seeking relief concerning Bonilla’s underlying conviction and the handling of his self-filed habeas petitions and other cases in state and federal court.

Filing-fee status

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That restriction permits fee-free filing only when the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such imminent danger, so Bonilla could not proceed without paying the filing fee.

Other grounds for dismissal

The court further stated that, even if an application to proceed without paying fees had been granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim explanation of which doctrine applied to which case.

Disposition

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