Bonilla v. Napa County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for violating federal rights. The complaints were nearly identical. Bonilla named various state superior courts and state judges as defendants and sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.

Filing-fee status

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That provision allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such a danger, so Bonilla could not proceed without paying the filing fee.

Other legal bars and disposition

The court further stated that, even if Bonilla's applications to proceed without paying fees were granted, the lawsuits would be barred under the restrictions identified by the court, including the rule against civil-rights claims that would undermine an existing conviction, the rule requiring federal courts to refrain from interfering with certain ongoing state proceedings, and other cited limits on these claims. The court therefore dismissed the cases with prejudice.

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