Bonilla v. Lake County

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal judges, state judges, municipalities, and other municipal and court officials. The opinion states that the complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his pro se habeas petitions and other cases by state and federal courts.

Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings. The opinion concerns multiple related case numbers, including 20-cv-02989-PJH and other listed cases.

Court’s analysis

The court stated that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). That restriction applied unless he was under imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger at the time of filing.

The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze the application of each cited rule to each case.

The court also rejected the suggestion that its impartiality could reasonably be questioned, citing the principle that a judge has a duty to decide assigned cases absent legitimate reasons for recusal.

Disposition

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The order was signed by United States District Judge Phyllis J. Hamilton.