Bonilla v. San Mateo County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal law that permits certain claims against government actors. He represented himself in these cases. The complaints were nearly identical and named several state courts, state judges, and other state and federal officials as defendants.

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

Ruling

The court addressed Bonilla's possible request to proceed in forma pauperis, meaning without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if he was in imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger. It therefore held that he could not proceed without paying the filing fees.

The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each rule's application to each complaint.

Disposition

Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases.