Bonilla v. Alameda County Superior Court Judges

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state actors. The complaints were nearly identical and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.

The court noted that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning that conviction.

Court’s analysis

The court held that Bonilla was barred from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.

The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would still be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It noted that Bonilla named the judge as a defendant in one of the cases.

Disposition

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 submitted in the closed cases.

Classification

This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal bars rather than deciding the underlying civil-rights claims on their merits.

Note on case identification

The caption visible in the opinion identifies the plaintiff as Steven Wayne Bonilla and the defendants as “U.S. DISTRICT COURT SAN FRANCISCO et. al.” The supplied case name identifies the case as Bonilla v. Alameda County Superior Court Judges.