Bonilla v. Monterey Cnty. Super. Ct.

Background

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

The order covered the following case numbers: 24-cv-6883-PJH, 24-cv-6885-PJH, 24-cv-6924-PJH, 24-cv-6925-PJH, 24-cv-7260-PJH, 24-cv-7261-PJH, 24-cv-7263-PJH, 24-cv-7264-PJH, 24-cv-7265-PJH, 24-cv-7311-PJH, 24-cv-7312-PJH, 24-cv-7313-PJH, 24-cv-7315-PJH, 24-cv-7316-PJH, 24-cv-7319-PJH, 24-cv-7320-PJH, 24-cv-7321-PJH, 24-cv-7322-PJH, 24-cv-7323-PJH, 24-cv-7378-PJH, 24-cv-7380-PJH, 24-cv-7381-PJH, and 24-cv-7382-PJH.

Filing-fee status

The court addressed Bonilla’s possible request to proceed in forma pauperis, meaning without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if the complaint shows that the prisoner faced an 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 concluded that he could not proceed without paying the filing fee.

Other barriers identified by the court

The court stated that, even if Bonilla’s application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not analyze the underlying merits of Bonilla’s claims.

Recusal issue

The court also addressed whether Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s repetitive filings. It concluded that these circumstances did not require recusal, citing the principle that a judge generally has a duty to hear assigned cases absent a legitimate reason for recusal. The order notes that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her in those cases.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It further directed the clerk to return, without filing, any additional documents Bonilla submits in the closed cases. The order also states that Bonilla has an extensive history of filing similar cases, but it does not separately identify a different disposition for any individual case number.