Bonilla v. Superior Court, County of San Francisco

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The listed defendants included federal judges, state judges, court staff, and state and federal agencies. The complaints presented similar claims seeking relief related to Bonilla’s underlying conviction and the handling of his other petitions and cases in state and federal court.

The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same district, with appointed counsel, and was represented by counsel in state-court proceedings.

Filing-fee ruling

Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless 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 show such imminent danger. The court therefore ruled that he could not proceed without paying the filing fee.

Other barriers to the lawsuits

The court further stated that, even if Bonilla’s application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain which rule applied to which individual case.

Disposition

The court dismissed the cases with prejudice. It also stated that the judge’s impartiality could not reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.