Bonilla v. Santa Cruz County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that permits certain claims against government officials acting under color of state law. The complaints were nearly identical. They named various federal and state judges and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the way other cases had been handled. The opinion also states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status

The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.

Additional grounds for dismissal

The court further stated that, even if an application to proceed without paying fees 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 opinion does not provide a separate analysis of how each cited rule applies to each individual case.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The court additionally stated that the repetitive and allegedly frivolous filings did not provide a basis to reasonably question the assigned judge’s impartiality. The opinion notes that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her.