Bonilla v. Kings County Superior Court

Background

Steven Wayne Bonilla, described by the court as a state prisoner, filed numerous cases without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government officials. The opinion covers the cases listed under Case Nos. 25-cv-5296-PJH, 25-cv-5351-PJH, 25-cv-5352-PJH, 25-cv-5353-PJH, 25-cv-5595-PJH, 25-cv-5596-PJH, 25-cv-5597-PJH, 25-cv-5598-PJH, 25-cv-5600-PJH, 25-cv-5601-PJH, 25-cv-5602-PJH, 25-cv-5603-PJH, 25-cv-5604-PJH, 25-cv-5605-PJH, 25-cv-5606-PJH, 25-cv-5900-PJH, 25-cv-5903-PJH, 25-cv-5905-PJH, 25-cv-5906-PJH, 25-cv-5907-PJH, 25-cv-5909-PJH, 25-cv-5910-PJH, 25-cv-5912-PJH, 25-cv-5915-PJH, 25-cv-5916-PJH, 25-cv-5917-PJH, 25-cv-5918-PJH, 25-cv-5920-PJH, 25-cv-6015-PJH, 25-cv-6051-PJH, 25-cv-6052-PJH, 25-cv-6054-PJH, 25-cv-6055-PJH, 25-cv-6056-PJH, 25-cv-6057-PJH, 25-cv-6058-PJH, 25-cv-6059-PJH, 25-cv-6060-PJH, 25-cv-6140-PJH, 25-cv-6141-PJH, 25-cv-6142-PJH, 25-cv-6143-PJH, 25-cv-6144-PJH, 25-cv-6273-PJH, and 25-cv-6274-PJH.

The cases named various federal judges, state judges, state courts, and law-enforcement officials. The opinion says Bonilla presented nearly identical claims seeking relief related to his underlying conviction or the handling of his other cases in state and federal courts. It also notes that he had a pending federal petition with appointed counsel and was represented by counsel in state-court proceedings.

Court’s analysis

The court addressed Bonilla’s ability to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without fees 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 such danger, so he could not proceed without paying filing fees.

The court further stated that, even if Bonilla had been allowed to proceed without fees, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying validity of Bonilla’s conviction or the other court proceedings; it dismissed the cases based on the filing-fee restriction and the stated legal bars.

The court also considered whether the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It concluded that these circumstances did not require recusal. The opinion notes that Bonilla named Judge Hamilton as a defendant in one of the cases.

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. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases.