Bonilla v. Ventura County Court Clerk's Office

Background

Steven Wayne Bonilla, described in the opinion as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named numerous county clerk’s offices as defendants and presented nearly identical claims. Bonilla 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 challenge to his conviction and was represented by counsel in state-court proceedings challenging his conviction.

Filing-fee status

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.

Other grounds for dismissal

The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules discussed 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 analyze each rule’s application to each complaint.

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 those closed cases. Judge Phyllis J. Hamilton signed the order.