Bonilla v. Superior Court, County of San Benito

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various federal judges, state judges, counties, and federal agencies as defendants. The court said the complaints presented very similar claims concerning Bonilla's underlying conviction and the handling of his other self-filed petitions and cases.

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

Court's analysis

The court addressed Bonilla's request, or possible request, to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified under that statute may proceed without paying only if the complaint shows that he was in immediate danger of serious physical injury when he filed it. The court found that the allegations did not show such danger.

The court further stated that, even if Bonilla's request to proceed without paying were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, which can bar civil-rights claims that would undermine a conviction or sentence; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; and Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court, which the court also cited as barriers to the lawsuits.

Disposition

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 the closed cases. Judge Phyllis J. Hamilton signed the order.