Bonilla v. San Benito County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various state superior courts and state judges as defendants. The court said the complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.

The court also noted that Bonilla had a pending federal petition concerning his imprisonment in the same court with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and legal barriers

The court addressed Bonilla’s request, or possible request, to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if he was facing an imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the filing fee.

The court further stated that, even if Bonilla’s request to proceed without paying the filing fee were granted, the lawsuits would still be barred under several authorities: Heck v. Humphrey, which can prevent civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; and Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court.

Disposition

The court dismissed the cases with prejudice. It directed 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.