Bonilla v. Del Norte County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal civil-rights statute. He represented himself in these cases. The complaints named various state courts and federal judges as defendants and sought relief concerning Bonilla's underlying conviction or the way his other state and federal cases had been handled.

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

Filing-fee status

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

Other barriers identified by the court

The court further stated that, even if Bonilla's request to proceed without paying the filing fee were granted, the lawsuits would be barred under rules and precedents cited by the court, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately analyze each complaint or explain which cited rule applied to each individual claim.

Ruling

The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of Bonilla's filings did not provide a basis to reasonably question the assigned judge's impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any additional documents Bonilla submitted in the closed cases.