Bonilla v. Mendocino County Superior Court

Background

Steven Wayne Bonilla, a condemned state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a federal law that permits certain claims against state actors. The complaints were nearly identical. They named various state courts and agencies as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases. The opinion also notes that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.

Filing-Fee Restriction

Bonilla sought, or potentially sought, permission to proceed without paying the filing fees. The court explained that 28 U.S.C. § 1915(g) disqualified him from proceeding without those fees unless he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.

Other Bars to the Lawsuits

The court further stated that, even if Bonilla’s request to proceed without paying fees were granted, the lawsuits would be barred under legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and claims against federal courts or court-related defendants. The opinion did not resolve the underlying allegations in Bonilla’s favor or the defendants’ favor.

Ruling

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