Bonilla v. El Dorado County Superior Court

Background

Steven Wayne Bonilla, a state prisoner sentenced to death, filed numerous complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government actors. The complaints were nearly identical and named various federal judges, state judges, state courts, and law-enforcement officials as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other cases. The order covers the case numbers listed in the caption, including 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.

Reasoning

The court addressed Bonilla's request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying dismissals generally may not proceed without prepaying the fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when it was filed. The court found that Bonilla's allegations did not show such danger.

The court further held that, even if Bonilla's request 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, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate merits determination on the underlying claims. It also rejected recusal, or removal of the judge because of a possible question about impartiality, reasoning that repetitive and frivolous filings alone did not provide a legitimate basis 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.