Bonilla v. Sonoma County

Background

Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints presented nearly identical claims and named dozens of federal and state judges as defendants. Bonilla sought relief related to his underlying conviction and the way state and federal courts handled his other cases. The opinion also states that he had a pending federal petition concerning his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee ruling

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only when the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show such danger. It therefore concluded that he could not proceed without paying the filing fee.

Other grounds identified by the court

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 or doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of those grounds.

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 the closed cases. The court also rejected the asserted basis for questioning Judge Hamilton's impartiality, stating that the repetitive and frivolous nature of the filings did not justify recusal. The order was signed by Judge Phyllis J. Hamilton.