Bonilla v. Lee

Background

Steven Wayne Bonilla, a condemned state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. The complaints were nearly identical. They sought relief concerning Bonilla’s underlying conviction and the handling of his other self-filed habeas petitions and cases in state and federal courts. The opinion also notes that Bonilla had appointed counsel in a pending federal habeas petition and was represented by counsel in state habeas proceedings.

Filing-fee status

The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under the “three strikes” provision, 28 U.S.C. § 1915(g). That provision allows such a prisoner to proceed without paying fees only if the complaint shows that he was in immediate danger of serious physical injury when he filed it. The court found that these complaints did not show such danger. Therefore, Bonilla could not proceed without paying the filing fees.

Other legal barriers

The court further stated that, even if a filing-fee waiver were granted, the lawsuits would be barred under several legal doctrines and precedents: Heck v. Humphrey, concerning civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, concerning interference with certain ongoing state proceedings; and the rules discussed in Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each complaint or explain each doctrine in detail.

Ruling

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The order was signed by Judge Phyllis J. Hamilton.