Bonilla v. Wright

Background

Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983. Section 1983 is a federal law that allows claims against state officials for violations of federal rights. The complaints named numerous state and federal judges and county clerks as defendants.

The court said the complaints presented nearly identical claims seeking relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases. The opinion also noted that Bonilla had a pending federal petition in the same court with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee restriction

To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing. Therefore, he could not proceed without paying the filing fee.

Other legal bars and disposition

The court further stated that, even if Bonilla’s applications to proceed without paying 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 did not separately explain the application of each cited decision.

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The ruling disposed of the cases on filing-status and other legal-bar grounds rather than deciding the underlying civil-rights claims on their merits.