Bonilla v. Contra Costa County Superior Court

Background

Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The court said the complaints presented nearly identical claims seeking relief related to Bonilla’s underlying conviction or the handling of his other cases by state and federal courts. The opinion also noted that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel, and that he was represented by counsel in state proceedings concerning that petition.

Filing-fee ruling

The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fee.

Other legal barriers

The court further stated that, even if Bonilla’s applications to proceed without paying the fee were granted, the lawsuits would be barred under one or more of the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate merits determination for each claim.

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. The court also rejected the contention that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. Judge Phyllis J. Hamilton signed the order.