Bonilla v. Shasta County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed numerous similar complaints under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against government officials. He represented himself in these cases. The complaints 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 in state and federal court.

The order states that Bonilla had a pending federal petition challenging his custody in this court, with appointed counsel, and was also represented by counsel in state-court proceedings concerning his custody.

Court’s reasoning

The court stated that Bonilla had been barred from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.

The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules cited in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court also noted Bonilla’s extensive history of filing similar cases.

The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The order noted that Bonilla named Judge Hamilton as a defendant in one of the cases but did not identify a legitimate reason requiring the judge to step aside.

Disposition

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