Bonilla v. San Benito County

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The cases named dozens of federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other state and federal cases. The opinion also states that he had a pending federal petition challenging his detention in that court with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and legal bars

The court explained that Bonilla had previously been 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 complaints. The court found that the allegations did not show such danger, so Bonilla could not proceed without paying the fee.

The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide whether Bonilla's underlying conviction or the handling of his other cases was legally correct.

Ruling

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.

The court also found that its judge's impartiality could not reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion notes that Bonilla named Judge Hamilton as a defendant in one case but states that the complaint made no specific allegations against her; the available text of the footnote ends there.