Bonilla v. Contra Costa County Superior Court

Background

Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple similar complaints under 42 U.S.C. § 1983, the federal civil-rights statute for claims against state actors. The listed cases included numerous docket numbers. The complaints named various federal judges, state judges, and state courts as defendants.

Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled. The opinion states that he had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings concerning the same general subject.

Court’s Analysis

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

The court further stated that, even if Bonilla had been allowed to proceed without prepaying fees, the lawsuits would be barred under the rules and precedents identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying claims in Bonilla’s favor or the defendants’ favor; it disposed of the cases on filing-status and legal-bar grounds.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The opinion noted that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her in those cases.

Disposition

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