Bonilla v. Chhabria

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 state courts, federal judges, and court officials. The complaints presented very similar claims seeking relief concerning Bonilla’s underlying conviction and the handling of his self-filed habeas petitions and other cases.

The order also noted that Bonilla had a pending federal habeas petition in the district court with appointed counsel and was represented by counsel in state habeas proceedings.

Court’s analysis

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 was in immediate danger of serious physical injury when he filed the complaints. The allegations did not show that he faced such danger.

The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal rules identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying validity of Bonilla’s conviction or the merits of his claims about the handling of his other cases.

The court also stated that these cases were not ones in which the assigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.

Disposition

Judge Phyllis J. Hamilton dismissed the cases with prejudice. 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.