Bonilla v. California Supreme Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute. The complaints were filed without a lawyer and presented nearly identical claims. The defendants included various federal and state courts. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled.

The order identifies the related case numbers as 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. The court also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings concerning his custody.

Court’s analysis

To the extent Bonilla sought permission to proceed without paying the filing fee, the court applied 28 U.S.C. § 1915(g). That provision prevents a prisoner who has been disqualified under the statute from proceeding without paying the fee unless the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the filing fee.

The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate discussion explaining how each cited decision applied to each complaint.

Disposition

The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. The order was signed by Judge Phyllis J. Hamilton on June 27, 2023.