Bonilla v. Alameda County et. al.

Background

Steven Wayne Bonilla, a state prisoner, filed four civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal judges, state judges, and other government officials and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.

The opinion states that Bonilla had a pending federal petition challenging his detention, with appointed counsel, and was also represented by counsel in state-court proceedings related to that petition.

Reasons for dismissal

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

The court further stated that, even if Bonilla had been allowed to proceed without paying the fees, the lawsuits would be barred under several legal rules. Those rules included limits on civil-rights claims that would undermine an existing conviction, restrictions on federal interference with ongoing state proceedings, and rules concerning challenges to federal court proceedings. The court did not decide the underlying claims in Bonilla’s complaints.

Ruling and case status

The court dismissed all four cases with prejudice. It also said that the repetitive and frivolous nature of the filings did not provide a basis to question the presiding judge’s impartiality. Judge Phyllis J. Hamilton ordered the clerk 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.