Bonilla v. San Mateo 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 as defendants and sought relief concerning Bonilla's underlying conviction or the way other state and federal court cases had been handled. The opinion also states that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state court proceedings concerning that petition.

Filing-fee restriction

The court addressed Bonilla's requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior dismissals generally cannot proceed without paying the fees unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from proceeding without paying fees and that these complaints did not show such an imminent danger. Therefore, he could not proceed without paying the filing fees.

Other stated bars

The court further stated that, even if a request to proceed without paying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not specify which cited bar applied to each individual case. The court also rejected any suggestion that its impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.