Bonilla v. San Mateo County Superior Court

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, and superior courts. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his petitions and other cases in state and federal court.

The opinion states that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings. The court also noted that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), which limits that status for a prisoner who has accumulated qualifying prior dismissals.

Court’s Analysis

The court found that the complaints did not show Bonilla faced an immediate danger when he filed them. As a result, he could not proceed without paying the filing fees. The court further stated that, even if an application to proceed without paying fees were 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 court also addressed whether the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It concluded that these cases did not present a basis for questioning the undersigned judge’s impartiality.

Disposition

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