Bonilla v. Hamilton

Background

Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order addresses the case numbers listed in its caption. Bonilla presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. He sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts.

The opinion states that Bonilla had a pending federal petition challenging his conviction in the same court with appointed counsel and was also represented by counsel in state-court proceedings concerning that petition. The court also noted Bonilla’s extensive history of filing similar cases.

Filing-fee status and legal barriers

The court considered whether Bonilla could proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying fees only if the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla’s allegations did not show such danger, so he could not proceed without paying the fees.

The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain the application of each cited rule to each individual case.

Ruling

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

The order also addressed whether Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. The court concluded that these were not cases requiring the judge to step aside. The order notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.

Classification

This is a procedural order. The court dismissed the cases based on filing-fee restrictions and legal barriers to the lawsuits, rather than deciding the underlying civil-rights claims on their merits.