Bonilla v. Santa Clara County

Background

Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion lists these case numbers: 22-cv-0275-PJH, 22-cv-0381-PJH, 22-cv-0432-PJH, 22-cv-0433-PJH, 22-cv-0666-PJH, 22-cv-0883-PJH, 22-cv-0885-PJH, 22-cv-0886-PJH, 22-cv-0888-PJH, 22-cv-0925-PJH, 22-cv-0966-PJH, 22-cv-0967-PJH, 22-cv-0968-PJH, and 22-cv-0969-PJH.

The complaints presented nearly identical claims and named dozens of federal and state judges as defendants. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. The opinion also notes that he had a pending federal petition challenging his confinement with appointed counsel and was represented by counsel in state-court proceedings.

Court’s analysis

The court addressed Bonilla’s possible request to proceed in forma pauperis, meaning without prepaying the filing fee. It found that the complaints did not show he was in imminent danger of serious physical injury when he filed them. The court therefore ruled that he could not proceed without paying the filing fee.

The court added that, even if an application to proceed without prepaying fees 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 the underlying allegations in Bonilla’s complaints on their merits.

The court also rejected the need for the judge to step aside based on the repetitive and frivolous nature of the filings, stating that the circumstances did not provide a basis to reasonably question the judge’s impartiality.

Ruling

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