Bonilla v. Behnke

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.

The order concerns the following related cases: 25-cv-6353-PJH, 25-cv-6847-PJH, 25-cv-6849-PJH, 25-cv-6896-PJH, 25-cv-6899-PJH, 25-cv-6952-PJH, 25-cv-6953-PJH, 25-cv-6954-PJH, 25-cv-6957-PJH, 25-cv-6958-PJH, 25-cv-6959-PJH, 25-cv-6960-PJH, 25-cv-6961-PJH, 25-cv-6963-PJH, 25-cv-6964-PJH, 25-cv-7008-PJH, 25-cv-7009-PJH, 25-cv-7010-PJH, 25-cv-7011-PJH, 25-cv-7012-PJH, 25-cv-7014-PJH, 25-cv-7029-PJH, 25-cv-7030-PJH, 25-cv-7047-PJH, 25-cv-7049-PJH, 25-cv-7051-PJH, 25-cv-7052-PJH, 25-cv-7153-PJH, 25-cv-7154-PJH, 25-cv-7155-PJH, 25-cv-7156-PJH, and 25-cv-7158-PJH.

Filing-fee restriction

The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute contains an exception when a prisoner is in imminent danger of serious physical injury at the time the complaint is filed. The court found that the allegations in these complaints did not show that Bonilla faced such danger when he filed them. The court therefore concluded that he could not proceed without paying the filing fees.

Other legal barriers

The court further stated that, even if an application to proceed without paying filing fees 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 did not provide a separate claim-by-claim explanation of how each cited decision applied to each complaint.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned merely because Bonilla had filed repetitive and frivolous cases. The order noted that Bonilla named Judge Hamilton as a defendant in three of the cases but presented no specific allegations against her.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.

Classification note

This is a procedural order because the court dismissed the cases based on filing-fee restrictions and legal bars without deciding the underlying civil-rights claims on their merits.