Bonilla v. County Clerk's Office

Background

Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion describes him as a condemned prisoner with a pending federal petition challenging his detention and conviction, for which he had appointed counsel. It also states that he was represented by counsel in state-court proceedings.

The complaints presented very similar claims. Bonilla sought relief concerning his underlying conviction or the way state and federal courts had handled his other cases.

Ability to Proceed Without Paying Filing Fees

Bonilla was disqualified from proceeding in forma pauperis, meaning without paying the filing fees, under 28 U.S.C. § 1915(g). The court stated that this restriction applied unless he showed that he was under imminent danger of serious physical injury when he filed his complaints.

The court found that the allegations did not show imminent danger at the time of filing. It therefore ruled that Bonilla could not proceed without paying the filing fees.

Other Grounds and Disposition

The court further stated that, even if an application to proceed without paying fees 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, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those grounds.

The court dismissed the cases with prejudice. It ordered 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.