Bonilla v. Mendocino County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state judges and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.

The order noted that Bonilla had a pending federal petition challenging his imprisonment in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings. The order also noted Bonilla’s history of filing similar cases.

Ruling

The court ruled that Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Accordingly, Bonilla could not proceed without paying the filing fee.

The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not assign each doctrine to particular claims or explain separately how each doctrine applied.

Disposition

The court dismissed the 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 those closed cases.

The order additionally stated that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. The opinion states that Bonilla named the judge as a defendant in one of the cases but provides no further detail about that case in the supplied text.