Bonilla v. Marin County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints asserted nearly identical claims and named dozens of federal and state judges, state courts, and federal officials as defendants. Bonilla sought relief concerning 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 challenging his conviction in the same court, with appointed counsel.

Filing-fee restriction

The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), subject to an exception if he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. Therefore, Bonilla could not proceed without paying the filing fee.

Other legal bars

The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee had been granted, the lawsuits would be barred under the rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each rule’s application to each complaint.

Ruling

Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed 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. The judge additionally declined to recuse herself, explaining that the repetitive and frivolous nature of the filings did not by itself provide a reasonable basis to question her impartiality; a footnote states that Bonilla named her as a defendant in one case but presented no legitimate reason for recusal.