Bonilla v. Solano County Court Clerk's Office

Background

Steven Wayne Bonilla, identified in the opinion as a state prisoner and a condemned prisoner, filed multiple similar lawsuits without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The cases named numerous county clerk’s offices as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts. The opinion also notes that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings challenging his custody.

Court’s analysis

The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under the three-strikes provision of 28 U.S.C. § 1915(g). That provision allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the filing fee.

The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and certain attacks on other court proceedings.

Disposition

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