Bonilla v. Tulare County Court

Background

Steven Wayne Bonilla, identified in the opinion as a state prisoner and a condemned prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The cases named numerous county clerk’s offices as defendants and presented nearly identical claims. The complaints sought relief concerning Bonilla’s underlying conviction and the handling of his other cases by state and federal courts.

Filing-fee ruling

The court addressed Bonilla’s request, to the extent he sought to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without fees may do so only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified under that provision and that his allegations did not show the required imminent danger.

Other legal barriers

The court further stated that, even if Bonilla’s request to proceed without paying fees were granted, the lawsuits would be barred under the rules and doctrines 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 provide a separate, claim-by-claim analysis of those barriers.

Disposition

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 order was signed by Judge Phyllis J. Hamilton.

Review note

The supplied case name refers to Tulare County Court, but the opinion’s caption identifies the defendant as Sierra County Clerk’s Office and lists multiple related case numbers. This summary follows the opinion’s caption.