Bonilla v. Mendocino County

Background

Steven Wayne Bonilla, identified in the order as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law allowing claims against state actors for violating federal rights. The complaints were filed without a lawyer and presented nearly identical claims. Bonilla named dozens of federal and state judges as defendants and sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.

The order also noted that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings concerning his imprisonment.

Filing-fee status and legal barriers

Bonilla sought, or might have sought, permission to proceed without prepaying filing fees. The court applied 28 U.S.C. § 1915(g) and found that the complaints did not show he was in imminent danger of serious physical injury at the time he filed them. The court therefore stated that he could not proceed without paying the required fees.

The court further stated that, even if permission to proceed without prepaying fees were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, concerning certain civil-rights claims that would undermine a criminal conviction; Younger v. Harris, concerning federal interference with certain ongoing proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court.

Ruling

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The order also rejected any suggestion that the judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.

The order resolved the cases on filing-fee and other legal-bar grounds rather than deciding the underlying civil-rights claims on their merits.