Bonilla v. Lake County

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows certain claims against government officials. He represented himself in these cases. The complaints presented nearly identical claims and named several counties and state and federal officials as defendants.

Bonilla sought relief concerning his underlying conviction or the way his other state and federal court cases had been handled. The opinion also states that he was a condemned prisoner, had a pending federal petition with appointed counsel, and was represented by counsel in state court proceedings.

Court’s reasoning

The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without prepaying the fee may do so only if the complaint shows that the prisoner was facing an imminent danger of serious physical injury when the complaint was filed. The court determined that these complaints did not show such danger, so Bonilla could not proceed under that fee-waiver process.

The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under several legal authorities: Heck v. Humphrey, which concerns civil-rights claims that would undermine a conviction or sentence; Younger v. Harris; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton on September 12, 2022.