Bonilla v. Sonoma County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints named various state courts and federal judges as defendants. Bonilla sought relief concerning his underlying conviction and the way state and federal courts had handled his other cases. The opinion lists 22 related case numbers.

Reasons for dismissal

The court addressed Bonilla’s requests to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without prepaying the filing fee unless the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the fees.

The court further stated that, even if a filing-fee waiver were granted, the lawsuits would be barred by rules and doctrines identified in the opinion, including the rule concerning civil-rights claims that would undermine a conviction, the rule requiring federal courts to avoid interfering with certain ongoing state proceedings, and other limits on challenges to federal court proceedings. The court also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings.

Ruling

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submits in those closed cases. Judge Phyllis J. Hamilton signed the order.