Bonilla v. San Mateo County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims against various state superior courts and state judges. The opinion says Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.

The opinion also notes that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel. It further states that he is represented by counsel in state-court proceedings concerning a similar petition.

Filing-Fee Status and Legal Bars

To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he faced an imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not make that showing.

The court further stated that, even if Bonilla had been allowed to proceed without paying the fee, the lawsuits would be barred under several authorities, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not analyze the underlying claims on their merits.

Disposition

Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.

Classification

This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal barriers rather than deciding whether Bonilla was right on the underlying claims.