Bonilla v. Napa County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state actors. The complaints named state superior courts and officials involved in Bonilla’s criminal prosecution. The court said the complaints presented nearly identical claims and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.

The opinion also noted that Bonilla was a condemned prisoner with a pending federal petition in the same court, in which he had appointed counsel. It further stated that he was represented by counsel in state-court proceedings.

Filing-fee ruling

The court addressed Bonilla’s ability to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status generally may proceed without prepaying fees only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such imminent danger. Therefore, he could not proceed without prepaying the filing fees.

Other grounds for dismissal

The court additionally stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the 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 separately explain the application of each doctrine to each case.

Disposition

The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.