Bonilla v. Humboldt County

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints were nearly identical and named dozens of federal and state judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal courts.

The opinion states that Bonilla had a pending federal petition concerning his conviction in the same court with appointed counsel and was also represented by counsel in state-court proceedings concerning that petition.

Filing-fee status and dismissal

The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fee.

The court further stated that, even if an application to proceed without paying the filing fee had been granted, the lawsuits would be barred under the legal rules and decisions identified in the opinion, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice.

Recusal and final orders

Bonilla named Judge Hamilton as a defendant in one of the cases. The court stated that the complaints did not provide specific allegations against her and that the repetitive and frivolous nature of the filings did not reasonably call her impartiality into question. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide assigned cases.

Judge Phyllis J. Hamilton ordered the clerk to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.