Bonilla

Background

Steven Wayne Bonilla, identified as a state prisoner, filed five similar civil-rights complaints under 42 U.S.C. § 1983, the federal statute that permits certain claims against people acting under state law. He represented himself in these cases. The complaints sought relief concerning his underlying conviction or the way other state and federal court cases had been handled. The opinion states that he named no specific defendants.

The opinion also states that Bonilla was a condemned prisoner with a pending federal petition challenging his detention or conviction in the same court, where he had appointed counsel. It further states that he was represented by counsel in state court proceedings concerning such a petition.

Reasons for dismissal

The court addressed Bonilla's request, to the extent he sought it, to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show imminent danger at that time.

The court added that, even if Bonilla had been allowed to proceed without paying the fees, the lawsuits would still be barred under legal doctrines and rules identified in the order, including rules concerning challenges to convictions, interference with ongoing proceedings, and certain attacks on court proceedings.

Ruling and effect

Judge Phyllis J. Hamilton ordered that the five cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. The order does not identify specific defendants or decide the underlying claims on their merits; it disposes of the cases based on the filing-fee restriction and the additional legal bars cited by the court.