Bonilla v. Anthony

Summary

The United States District Court for the Northern District of California dismissed multiple pro se civil rights actions filed by condemned prisoner Steven Wayne Bonilla. The court concluded that the complaints did not establish imminent danger for purposes of the in forma pauperis exception and that the claims would be barred by doctrines including Heck, Younger, Demos, and Mullis; the cases were dismissed with prejudice.

Holdings

1. Because Bonilla had been disqualified from proceeding in forma pauperis under § 1915(g) and his complaints did not show that he was under imminent danger of serious physical injury when he filed them, he could not proceed in forma pauperis.
2. Even if the in forma pauperis applications 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.
3. The multiple cases were dismissed with prejudice.

Questions Presented

1. Whether Bonilla could proceed in forma pauperis despite his prior disqualification under 28 U.S.C. § 1915(g).
2. Whether the complaints were barred by Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court.
3. Whether the multiple complaints should be dismissed with prejudice.

Disposition

dismissed