Bonilla v. Madera County Court Clerks Office

Background

Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal statute that permits certain claims against state actors. The complaints were nearly identical. They named numerous county clerks and state superior courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court. The opinion also states that Bonilla had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings.

Court’s Reasoning

The court addressed Bonilla’s ability to proceed without prepaying filing fees, commonly called proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court stated that Bonilla had been disqualified from proceeding that way unless he was in imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show imminent danger at that time.

The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not analyze each rule separately or explain which rule applies to which 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 the closed cases. Judge Phyllis J. Hamilton signed the order.