Bonilla v. Mendocino County Superior Court

Background

Steven Wayne Bonilla, described in the order as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The defendants included various state superior courts and state judges. The complaints sought relief concerning Bonilla’s underlying conviction and the way state and federal courts had handled his other cases.

The order also noted that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings concerning such a petition.

Proceeding Without Paying the Filing Fee

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That restriction can be overcome only if a complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger. Bonilla therefore 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 order did not provide a separate claim-by-claim analysis of those rules.

Disposition

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases. This was a procedural order because the court disposed of the cases on filing-fee and other threshold grounds rather than deciding the underlying civil-rights claims on their merits.