Bonilla v. Superior Court of California County of Mendocino

Background

Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers the following related case numbers: 22-cv-1900-PJH, 22-cv-2674-PJH, 22-cv-2776-PJH, 22-cv-2871-PJH, 22-cv-2872-PJH, 22-cv-3247-PJH, 22-cv-3248-PJH, 22-cv-3275-PJH, 22-cv-3276-PJH, 22-cv-3318-PJH, 22-cv-3319-PJH, 22-cv-3322-PJH, 22-cv-3421-PJH, 22-cv-3422-PJH, 22-cv-3423-PJH, 22-cv-3424-PJH, 22-cv-3425-PJH, 22-cv-3445-PJH, 22-cv-3446-PJH, 22-cv-3447-PJH, 22-cv-3448-PJH, 22-cv-3449-PJH, and 22-cv-3450-PJH.

The court said the complaints were nearly identical. They named dozens of federal and state judges, state courts, and federal officials as defendants, and sought relief concerning Bonilla's underlying conviction or the way other state and federal cases had been handled. The court also noted that Bonilla was a condemned prisoner and had a pending federal petition challenging his custody in the same court, with appointed counsel.

Court's reasoning

The court addressed Bonilla's possible request to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally may not proceed without paying unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified from using that fee-waiver process and that these complaints did not show the required imminent danger. Therefore, he could not proceed without paying the fees.

The court further stated that, even if a fee-waiver application had been granted, the lawsuits would be barred under the legal doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate analysis of each doctrine or identify which doctrine applied to which claim.

The court also addressed impartiality. Although Bonilla named Judge Hamilton as a defendant in one of the cases, the court stated that the repetitive and frivolous nature of the filings did not create a reasonable question about the judge's impartiality. The order cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.

Disposition

The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any additional documents Bonilla submitted in the closed cases. This was a procedural disposition based on the fee-waiver restriction and the legal bars identified by the court, rather than a decision resolving the underlying conviction-related claims on their merits.