Bonilla v. Calaveras County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute used for certain civil-rights claims. The complaints presented nearly identical claims and named various federal and state courts and government agencies as defendants. Bonilla sought relief concerning his underlying conviction or the way state and federal courts had handled his other cases. The opinion also states that he is a condemned prisoner with a pending federal petition challenging his custody, in which he has appointed counsel, and that he is represented by counsel in state-court proceedings.

Filing-fee status and legal barriers

The court stated that Bonilla had been disqualified from proceeding without paying 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 determined that the allegations did not show such imminent danger. It further stated that, even if an application to proceed without fees were granted, the lawsuits would be barred under 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 of these legal rules applied to which individual case or claim.

Ruling

Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The court also stated that the repetitive and allegedly frivolous filings did not provide a basis for reasonably questioning the judge’s impartiality. The opinion notes that Bonilla had filed many other similar cases, but it does not provide an individual merits analysis for each complaint.