Bonilla v. Gallagher

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple similar complaints without a lawyer under 42 U.S.C. § 1983, the federal law that allows certain civil-rights claims against state actors. The order covers the listed cases, including No. 25-cv-6189-PJH and numerous related case numbers. Bonilla named various federal judges, state judges, and state courts as defendants. The court said that his claims concerned his underlying conviction or the way his other cases had been handled by state and federal courts.

The order also noted that Bonilla has a pending federal petition challenging his imprisonment in this court with appointed counsel and is represented by counsel in state-court proceedings involving such a petition.

Filing-fee ruling

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law allows a disqualified prisoner to proceed without paying only if the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. He therefore could not proceed without paying the filing fee.

Dismissal

The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate explanation of how each doctrine applied to each individual case. It dismissed the cases with prejudice.

Recusal and case closure

The court said these were not cases in which its judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases. A footnote stated that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.

The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.

Classification

This is a procedural order. The court dismissed the cases based on the prisoner filing-fee restriction and threshold legal doctrines rather than deciding the underlying civil-rights claims on their merits.