Bonilla v. Riverside County Court Clerk's Office

Background

Steven Wayne Bonilla, described by the court as a state prisoner and condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named numerous state and federal judges and county clerks as defendants and sought relief concerning Bonilla’s underlying conviction and the way his other cases had been handled by state and federal courts.

Filing-fee status

The court addressed Bonilla’s possible request to proceed 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 the complaint shows that the prisoner faced an immediate 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 fee.

Other legal barriers

The court further ruled that, even if Bonilla’s request to proceed without paying the filing fee 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, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze which cited rule applied to which complaint.

Ruling and case status

The court dismissed the cases with prejudice. It also held that the cases did not present a situation in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.

Disposition

The multiple cases were dismissed with prejudice. The opinion does not state a separate disposition for each listed case number beyond directing that the cases be closed.