Bonilla v. Sierra County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights complaints without a lawyer under 42 U.S.C. § 1983. Section 1983 provides a way to seek relief for certain violations of federal rights by government actors. Bonilla named various federal judges, state judges, state courts, and law-enforcement officials as defendants. He sought relief concerning his underlying conviction and the handling of his other state and federal cases.

Filing-fee restriction

The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee up front, under 28 U.S.C. § 1915(g). That restriction has an exception when the prisoner shows that he faced imminent danger of serious physical injury when the complaint was filed. The court found that the complaints did not show such danger, so Bonilla could not proceed without paying the filing fee.

Other legal barriers and disposition

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 identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate merits determination for each complaint. The court dismissed the cases with prejudice.

The court also rejected the suggestion that its impartiality could reasonably be questioned because of the repetitive and frivolous filings. It noted that Bonilla named the judge as a defendant in one of the cases and stated that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.

Clerk’s instructions

The clerk was ordered 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.