Bonilla v. County of San Francisco

Background

Steven Wayne Bonilla, a state prisoner, filed multiple lawsuits under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against government actors. The cases were filed without a lawyer and had nearly identical claims. The defendants included various state courts and municipalities.

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

Proceeding Without Paying Fees

Bonilla was disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fees unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger.

Other Bars to the Lawsuits

The court stated that, even if Bonilla's applications to proceed without paying fees were granted, the lawsuits would still be barred under several legal doctrines and decisions: Heck v. Humphrey, which limits civil-rights claims that would undermine a conviction; Younger v. Harris, concerning federal interference with certain ongoing state proceedings; Demos v. U.S. District Court; and Mullis v. U.S. Bankruptcy Court. The order did not separately identify which claim was barred by which doctrine.

Disposition

The court dismissed the multiple cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton on August 28, 2023.