Bonilla v. Santa Clara County Superior Court

Background

Steven Wayne Bonilla, described by the court as a condemned state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983. The complaints presented nearly identical claims and named various federal and state judges and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the way his other cases had been handled.

The court noted that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was also represented by counsel in state proceedings challenging his imprisonment. The court further noted his history of filing similar cases.

Court’s reasoning

The court ruled that, to the extent Bonilla sought permission to proceed without paying filing fees, 28 U.S.C. § 1915(g) barred him from doing so unless he was in imminent danger of serious physical injury when he filed the complaints. The allegations did not show such imminent danger, so he could not proceed without paying the filing fees.

The court added that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the rules and doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not conduct a merits determination of Bonilla’s underlying conviction-related or case-handling claims.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The court noted that Bonilla named Judge Hamilton as a defendant in three cases but made no specific allegations against her in those cases.

Disposition

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