Bonilla v. Santa Cruz County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The cases were assigned multiple docket numbers, including 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, and 24-cv-3600-PJH.

Bonilla presented nearly identical claims and named various state courts and federal judges as defendants. The opinion says he sought relief concerning his underlying conviction and the handling of his other cases in state and federal court. It also states that he had a pending federal habeas case and was represented by counsel in state-court habeas proceedings.

Reason for dismissal

The court addressed Bonilla's ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla had been disqualified from proceeding without paying the fee and that his allegations did not show imminent danger at the relevant time.

The court further stated that, even if an application to proceed without paying the filing fee 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. The opinion does not explain which specific bar applied to which individual case.

The court also rejected any suggestion that the assigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion states that Bonilla named the judge as a defendant in one case but did not provide a legitimate basis for recusal.

Disposition

The court dismissed the cases with prejudice. It directed 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.

The order describes the cases as procedurally barred and does not decide the underlying validity of Bonilla's conviction or the merits of his civil-rights allegations.