Bonilla v. Barnes

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for certain constitutional violations. The order covers numerous cases, including Case No. 25-cv-6189-PJH and the other case numbers listed in the caption.

The complaints presented nearly identical claims and named various federal judges, state judges, and state courts as defendants. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. The order also notes that he had a pending federal petition challenging his detention with appointed counsel and was represented by counsel in state-court proceedings.

Court’s analysis

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

The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order also addressed whether Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings and concluded that recusal was not required.

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.