Bonilla v. Alameda County Superior Court, Its Judges and Clerks

Background

Steven Wayne Bonilla filed multiple nearly identical complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims. The order addresses multiple related cases, including case numbers 24-cv-3209-PJH, 24-cv-3212-PJH, 24-cv-3228-PJH, 24-cv-3238-PJH, 24-cv-3249-PJH, 24-cv-3342-PJH, 24-cv-3418-PJH, 24-cv-3419-PJH, 24-cv-3507-PJH, 24-cv-3509-PJH, 24-cv-3511-PJH, 24-cv-3514-PJH, 24-cv-3515-PJH, 24-cv-3516-PJH, 24-cv-3517-PJH, 24-cv-3533-PJH, 24-cv-3534-PJH, 24-cv-3537-PJH, 24-cv-3562-PJH, 24-cv-3563-PJH, 24-cv-3564-PJH, 24-cv-3600-PJH, and other listed cases. He named various state courts and federal judges as defendants and sought relief concerning his underlying conviction or the handling of his other cases.

The order states that Bonilla is a condemned prisoner, has a pending federal petition challenging his custody, and is represented by counsel in state-court custody proceedings. He filed these civil-rights complaints without a lawyer.

Reasons for Dismissal

The court addressed Bonilla's ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a person with the qualifying history described by the court may not proceed without paying unless the complaint shows that the person faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger. It therefore held that he could not proceed without paying the filing fees.

The court added that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under rules and doctrines identified in the order, including the rule limiting civil-rights suits that would undermine an existing conviction, the rule requiring federal courts in some circumstances to refrain from interfering with ongoing state proceedings, and authorities concerning challenges to court actions and federal judicial proceedings.

Disposition

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

Judge Phyllis J. Hamilton further rejected the suggestion that her impartiality could reasonably be questioned because of Bonilla's repetitive and allegedly frivolous filings. The order noted that Bonilla named the judge as a defendant in one case but, according to the order, presented no legitimate basis for recusal.