Bonilla v. San Quentin Administration

Background

Steven Wayne Bonilla, a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute that allows certain civil-rights claims against state actors. The complaints were nearly identical. They named dozens of federal and state judges and sought relief concerning Bonilla’s underlying conviction or the way other state and federal cases had been handled. The opinion also noted that Bonilla had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state custody-related proceedings.

Filing-fee status and legal barriers

Bonilla appeared to seek permission to proceed without paying the filing fees. The court applied the rule commonly called the “three strikes” provision, which generally prevents a prisoner with qualifying prior cases from proceeding without prepaying fees unless the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that the complaints did not show such danger, so Bonilla could not proceed without paying the fees.

The court added that, even if permission to proceed without paying had been granted, the lawsuits would be barred under several legal doctrines and decisions it cited, including rules concerning challenges to criminal convictions, interference with ongoing proceedings, and claims against judges or courts.

Ruling

The court dismissed the cases with prejudice. It also stated that these were not cases in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.