Bonilla v. Bruiniers

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The defendants included various federal and state court judges. The complaints presented similar claims seeking relief concerning Bonilla’s underlying conviction and the handling of his self-represented habeas petitions and other cases.

The opinion also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. The opinion states that Bonilla named Judge Hamilton as a defendant in one of the cases, but that complaint raised no specific allegations against her.

Filing-fee status and legal bars

The court held that Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger.

The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.

Ruling

Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The court also rejected the assertion that its impartiality could reasonably be questioned because of the repetitive and frivolous filings, stating that judges generally have a duty to decide cases assigned to them absent legitimate reasons for recusal.