Bonilla v. Stamps

Background

Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that permits claims against certain government actors. He was proceeding without a lawyer in these cases. The opinion states that he also had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state-court proceedings.

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 and the handling of his other state and federal cases.

Filing-fee status and barriers to the lawsuits

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

The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several authorities. Those included rules limiting civil-rights challenges that would undermine a conviction, restrictions on federal interference with certain ongoing proceedings, and restrictions on challenges to the actions of other courts. The opinion does not separately analyze the allegations in each case.

Ruling

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court also stated that the filings were repetitive and frivolous and rejected any suggestion that the judge’s impartiality could reasonably be questioned based on the filings. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submits in these closed cases.