Bonilla v. California Attorney General

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute used to sue state officials for alleged violations of federal rights. The complaints named several state officials and presented nearly identical claims. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.

The opinion states that Bonilla had a pending federal petition concerning his imprisonment in the same court with appointed counsel, and that he was also represented by counsel in state-court proceedings concerning his imprisonment.

Court’s reasoning

The court addressed Bonilla’s possible request to proceed without paying the filing fee, commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court said Bonilla had been disqualified from proceeding this way unless he showed that he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger.

The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey or Mullis v. U.S. Bankruptcy Court, as cited in the opinion. The court did not provide additional analysis of the individual claims.

Ruling and case status

The court dismissed the cases with prejudice. It ordered 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. Judge Phyllis J. Hamilton signed the order on July 29, 2022.