Bonilla v. County of Santa Clara

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints presented nearly identical claims, named several counties and state officials as defendants, and sought relief concerning Bonilla’s underlying conviction. The opinion also noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status

The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in immediate 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 grounds identified by the court

The court further stated that, even if Bonilla’s applications 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 did not decide the underlying claims on their merits.

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 additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.