Bonilla v. Sonoma County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute for claims against government officials acting under state law. 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 states that Bonilla had a pending federal petition challenging his detention in the same court, with appointed counsel, and was also represented by counsel in state-court proceedings. The court also noted his extensive history of filing similar cases.

Reasons for dismissal

The court said Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced an imminent danger of serious physical injury when he filed the complaints. The court found that the complaints did not show such a danger.

The court further stated that, even if Bonilla’s applications to proceed without paying filing fees were granted, the lawsuits would be barred by the rules and doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion therefore did not resolve the underlying challenges to Bonilla’s conviction or the handling of his other cases.

The court also stated that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question Judge Hamilton’s impartiality.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.