Bonilla v. Mayfield

Background

Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983, the federal statute that permits claims against state officials for violating federal rights. He proceeded without a lawyer in these cases. The complaints named various federal and state judges and other officials and sought relief related to Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.

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

Reasons for dismissal

The court ruled that, to the extent Bonilla sought permission to proceed without prepaying filing fees, 28 U.S.C. § 1915(g) disqualified him from doing so 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 stated that, even if Bonilla’s applications to proceed without prepaying 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, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain which particular bar applied to which case or claim.

Other ruling and disposition

The court rejected the suggestion that the repetitive and allegedly frivolous filings created a reasonable question about the undersigned judge’s impartiality. It cited the general rule that, absent legitimate reasons for recusal, an assigned judge has a duty to decide the cases.

The court dismissed the cases with prejudice. It ordered 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.