Bonilla v. Stanislaus County Court

Background

Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple similar civil-rights complaints without a lawyer under 42 U.S.C. § 1983, the federal law that permits certain claims against state actors. The caption identifies Sierra County Clerk’s Office and other defendants; the opinion says that Bonilla named numerous county clerk’s offices. He sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts. The opinion also states that he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that petition.

Fee-waiver ruling

The court addressed Bonilla’s possible requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot use that process unless he shows that he faced imminent danger of serious physical injury when the complaint was filed. The court cited prior proceedings and concluded that Bonilla had been disqualified from proceeding under that fee-waiver provision. It further found that his allegations did not show imminent danger at the time of filing. The opinion therefore states that he may not proceed without paying the filing fee.

Other bars and disposition

The court added that, even if a fee-waiver application 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 does not assign a separate rule to each individual claim. 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. Judge Phyllis J. Hamilton signed the order.