Bonilla v. False Arrest and Imprisonment

Background

Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983, the federal law that allows certain claims against state officials for violating federal rights. The complaints presented nearly identical claims and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The opinion also noted that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.

Court's analysis

The court stated that Bonilla had been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g), unless 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 ruled that, even if Bonilla's applications to proceed without prepaying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court also rejected any suggestion that the undersigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.

Disposition

Judge Phyllis J. 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.