Bonilla v. Amador County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state actors. 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 handled his other cases.

The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his imprisonment in the same district court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings concerning his imprisonment.

Reasons for dismissal

The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That provision generally prevents a prisoner with a qualifying history of unsuccessful or frivolous cases from using the fee-waiver process unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed.

The court found that Bonilla's allegations did not show imminent danger at the time of filing. It therefore ruled that he could not proceed without paying the filing fees. The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under several legal doctrines and authorities, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain how each cited bar applied to each individual case.

The court also rejected any suggestion that the judge's impartiality could reasonably be questioned because of Bonilla's repetitive and allegedly frivolous filings. The opinion stated that the judge had a duty to decide assigned cases absent legitimate grounds for recusal.

Disposition

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

The opinion notes that the judge was the fourth judge assigned to Bonilla's cases, that the judge had issued the 76th order concerning Bonilla's filings since April 30, 2020, and that Bonilla had filed 962 other cases with three other judges since 2011.