Bonilla v. Sacramento County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants. Bonilla sought relief relating to his underlying conviction and to the way his other state and federal cases had been handled.

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

Reasoning

The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute prevents a prisoner with the relevant filing history from proceeding without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger.

The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under the 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 provide a separate claim-by-claim analysis explaining which cited rule applied to which complaint.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion notes that Bonilla named Judge Hamilton as a defendant in one of the cases, but the available text ends before completing the footnote’s explanation.

Disposition

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 order does not state separate dispositions for individual claims or defendants.