Bonilla v. Monterey County Superior Court

Background

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

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

Court’s analysis

The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), the court said he was disqualified from proceeding without fees unless he was under imminent danger of serious physical injury when he filed the complaints. The court found that the complaints did not show such danger.

The court further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under the doctrines and decisions cited in the order, including 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 bars.

Disposition

Judge Phyllis Hamilton ordered that the cases be dismissed 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 additional documents Bonilla submitted in the closed cases.