Bonilla v. Monterey County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain claims against state actors. The complaints named various state superior courts and state judges. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases.

The opinion also states that Bonilla was a condemned prisoner with a pending federal petition challenging his conviction in the same court, where he had appointed counsel. It further states that he was represented by counsel in state-court proceedings.

Rulings

The court addressed Bonilla’s possible use of the fee-waiver process for people who cannot afford filing fees, known as proceeding in forma pauperis. Under 28 U.S.C. § 1915(g), the court stated that Bonilla had already been disqualified from using that process unless he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed under that fee-waiver process.

The court added that, even if a fee-waiver application 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 does not provide a separate claim-by-claim analysis of those grounds.

Disposition

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