Bonilla v. Superior Court of California, County of Napa

Background

Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983, the federal law that allows certain claims against state officials for violating federal rights. The opinion lists numerous related case numbers. Bonilla represented himself. The complaints presented nearly identical claims and named dozens of federal and state judges, state courts, and federal officials as defendants. The court said the complaints sought relief concerning Bonilla’s underlying conviction or the way other cases had been handled by state and federal courts.

The court also noted that Bonilla had a pending federal petition concerning his detention in the same court, with an appointed lawyer.

Reasoning

The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying the fee may do so only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court said Bonilla had previously been disqualified under that provision and that these complaints did not show an immediate danger at the relevant time. He therefore could not proceed without paying the filing 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 provide a separate merits determination of Bonilla’s underlying claims.

The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. A footnote states that Bonilla named the judge as a defendant in one of the cases but presented no legitimate reason for the judge to step aside.

Disposition

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

Classification

This is a procedural order. The court dismissed the cases based on Bonilla’s inability to proceed without paying the filing fee and on threshold legal bars, without deciding the underlying civil-rights claims on their merits.