Bonilla v. Tuolumne County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The complaints were nearly identical. They named various federal judges, state judges, state courts, and law-enforcement officials as defendants and sought relief concerning Bonilla's underlying conviction or the handling of his other cases. The opinion also states that Bonilla had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and claims

Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed under that fee-waiver procedure.

The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred by rules and doctrines identified in the opinion, including the rule limiting civil-rights claims that would undermine a conviction, the rule requiring federal courts to refrain from interfering with certain ongoing state proceedings, and authorities concerning claims against federal courts and judges.

Ruling

The court dismissed the cases with prejudice. It also rejected the contention that the judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings, noting that Bonilla named the judge as a defendant in one of the cases. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents submitted in the closed cases. Judge Hamilton also noted Bonilla's extensive history of filing similar cases.