Bonilla v. Mendocino County

Background

Steven Wayne Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer under 42 U.S.C. § 1983. He named dozens of federal and state judges as defendants and sought relief concerning his underlying conviction or the handling of his other cases in state and federal court. The opinion also notes that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel and was represented by counsel in state-court proceedings.

Proceeding Without Paying Filing Fees

To the extent Bonilla sought permission to proceed without paying filing fees, the court applied 28 U.S.C. § 1915(g). That provision disqualifies a prisoner from proceeding without paying fees after certain prior cases unless the prisoner was facing an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger. It therefore concluded that he could not proceed without paying the fees.

Other Bars to the Lawsuits

The court further stated that, even if Bonilla's request to proceed without paying fees were granted, his lawsuits would be barred under several legal doctrines and decisions, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, attacks on federal-court judgments, and claims against judges. The opinion identifies these authorities as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.

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 those closed cases. The court also rejected any claim that the judge's impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. Judge Phyllis J. Hamilton signed the order.