Bonilla v. County of Monterey

Background

Steven Wayne Bonilla, a state prisoner sentenced to death, filed multiple nearly identical civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints named several counties and state officials and sought relief concerning Bonilla’s underlying conviction. The opinion also states that Bonilla had a pending federal petition challenging his detention or conviction with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and legal bars

The court addressed Bonilla’s attempt to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status generally may not proceed without paying unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court found that Bonilla’s allegations did not show such danger.

The court further stated that, even if Bonilla were allowed to proceed without paying the fee, the lawsuits would be barred under several legal doctrines and decisions, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and limits on federal district-court review.

Ruling

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases. The order does not decide the underlying civil-rights allegations on their merits; it disposes of the cases based on filing-fee eligibility and other legal bars.