Bonilla v. United States District Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order addresses seven related cases: Nos. 23-cv-2507-PJH, 23-cv-2745-PJH, 23-cv-2746-PJH, 23-cv-2747-PJH, 23-cv-2776-PJH, 23-cv-2847-PJH, and 23-cv-2890-PJH.

Bonilla is a condemned prisoner who has a pending federal petition challenging his custody in the same court, where he has appointed counsel. He is also represented by counsel in state-court proceedings concerning his custody. The complaints in these cases presented nearly identical claims against various federal and state courts. Bonilla sought relief concerning his underlying conviction or the way state and federal courts handled his other cases.

Court’s Analysis

The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That restriction has an exception when a prisoner was in immediate danger of serious physical injury at the time the complaint was filed. The court found that Bonilla’s allegations did not show that he was in such danger.

The court further ruled that, even if Bonilla’s applications to proceed without paying filing fees were granted, the lawsuits would still be barred under the legal doctrines identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately explain the application of each doctrine to each complaint.

Disposition

Judge Phyllis J. Hamilton 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.