Bonilla v. San Francisco County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple related civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases involved nearly identical claims against several state courts, state judges, and state and federal officials. The complaints sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts.

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

Court’s reasoning

The court addressed Bonilla’s request, or possible request, to proceed in forma pauperis—meaning without paying the filing fee. 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 immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not make that showing.

The court further stated that, even if Bonilla’s request to proceed without paying the filing fee had been granted, the lawsuits would be barred under the 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 provide separate, claim-by-claim explanations of how each cited rule applied.

Disposition

The court dismissed the multiple 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.