Bonilla v. San Benito County Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state actors. The opinion lists numerous related case numbers, including 25-cv-6189-PJH and many others. Bonilla proceeded without a lawyer in these cases. He named various federal judges, state judges, and state courts as defendants, and sought relief concerning his underlying conviction and the handling of other proceedings in state and federal court.

The court noted that Bonilla had a pending federal petition concerning his imprisonment with appointed counsel and was also represented by counsel in state proceedings. The opinion also noted his history of filing similar cases.

Filing-fee restriction

Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. As a result, Bonilla could not proceed without paying the filing fee.

Other legal barriers and disposition

The court further ruled that, even if Bonilla had been allowed to proceed without paying the fee, the lawsuits would be barred under legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and claims against federal courts or judges. The court therefore dismissed the cases with prejudice.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned merely because of the repetitive and frivolous nature of the filings. 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.