Bonilla v. David Anthony et. al.

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute that permits certain claims against government actors. The complaints presented nearly identical claims against various federal judges, state judges, and other government officials. The opinion states that Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.

The opinion also states that Bonilla had a pending federal petition challenging his custody, in which he had appointed counsel, and was represented by counsel in state-court proceedings. The court noted Bonilla's history of filing similar cases.

Filing-fee restriction

The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court concluded that the allegations did not show imminent danger at the time of filing. Therefore, Bonilla could not proceed without paying the filing fee.

Other legal bars

The court further stated that, even if an application to proceed without paying the filing fee 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 opinion does not separately explain how each cited decision applied to each individual case.

The court also stated that the repetitive and frivolous nature of the filings did not provide a reason to question the impartiality of the judge handling these cases. It cited the rule that, absent legitimate grounds for disqualification, a judge has a duty to decide assigned cases.

Ruling and case status

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The order does not describe this as a ruling on the merits of the underlying conviction-related or case-handling claims; it relies on the filing-fee restriction and the additional legal bars. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.

The opinion notes that the undersigned judge was the fourth judge assigned cases filed by Bonilla and that the judge had issued an order in 1,302 different cases involving Bonilla since April 30, 2020.