Bonilla v. Sonoma County Superior Court

Background

Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. He named various state courts and agencies as defendants. The complaints presented nearly identical claims concerning his underlying conviction and the way state and federal courts handled his other cases.

The order also noted that Bonilla had a pending federal petition challenging his custody in the same district with appointed counsel, and that he was represented by counsel in state-court proceedings concerning his custody.

Filing-fee status

Bonilla sought, or appeared to seek, permission to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying the fee unless he was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had been disqualified under that provision and found that his allegations did not show imminent danger at the time of filing. The court therefore ruled that he could not proceed without paying the filing fee.

Other legal bars and disposition

The court further stated that, even if a filing-fee application were granted, the lawsuits would be barred under the doctrines and authorities identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not resolve the underlying civil-rights claims on their merits.

Judge Phyllis Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any additional documents Bonilla submitted in the closed cases. The order also noted Bonilla’s extensive history of filing similar cases.