Bonilla v. El Dorado County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute. He was representing himself in these cases. The defendants included various state superior courts, state judges, and federal judges in the Eastern District of California.

Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases. The order also noted that he had a pending federal petition challenging his conviction in this district with appointed counsel, and that he was represented by counsel in state-court proceedings concerning that challenge.

Court’s analysis

The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That provision permits a disqualified prisoner to proceed without paying fees only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger.

The court further ruled that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate merits determination for each complaint or claim.

Disposition

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