Bonilla v. County of Sonoma

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, the federal statute that permits certain civil-rights claims against government actors. The complaints presented nearly identical claims and named various state courts and municipalities as defendants. The opinion says Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.

The opinion also notes that Bonilla had a pending federal petition in the same district court with appointed counsel and was represented by counsel in state-court proceedings. Those matters were cited as related proceedings, not decided in this order.

Court’s reasoning

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

The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under the rules and 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 opinion does not separately explain how each cited authority applied to each complaint.

Ruling and case status

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