Bonilla v. Monterey County

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. That statute provides a federal cause of action for certain constitutional-rights violations by people acting under state law. The complaints named various federal and state judges and a correctional officers’ union as defendants. The court said the complaints presented very similar claims and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts handled his other cases.

Proceeding Without Paying Filing Fees

Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Accordingly, the court ruled that Bonilla could not proceed without paying the filing fees.

Other Grounds Identified by the Court

The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines and precedents cited in the order, including doctrines concerning challenges to criminal convictions, interference with ongoing state proceedings, and claims against federal judges or courts. The opinion did not conduct a merits determination that Bonilla’s underlying conviction or the handling of his other cases was lawful.

Disposition

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

Anonymization and Caption Note

The supplied case name identifies Monterey County, but the opinion’s caption names Judge Clarence Don Clay and other defendants. This summary follows the opinion’s caption.