Bonilla v. Superior Court of Santa Clara 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 complaints named various federal judges, state judges, and superior courts as defendants. The court said the cases presented very similar claims concerning Bonilla’s underlying conviction and the handling of his petitions and other matters in state and federal court.

The opinion also stated that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.

Court’s reasoning

Bonilla sought, or could have sought, permission to proceed without paying the filing fee, known as proceeding in forma pauperis. The court said he had already been disqualified from that status under 28 U.S.C. § 1915(g). The complaints also did not show that he faced an immediate danger when he filed them, so he could not proceed without paying the fee.

The court further stated that, even if permission to proceed without paying the fee had been granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those rules.

The court also rejected the suggestion that the assigned judge’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.

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.