Bonilla v. Leedy

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute that allows claims against state actors for certain constitutional violations. He filed the complaints without a lawyer. The order lists numerous related case numbers, including 22-cv-5344-PJH, 22-cv-5364-PJH, 22-cv-5370-PJH, 22-cv-5388-PJH, 22-cv-5389-PJH, 22-cv-5390-PJH, 22-cv-5394-PJH, 22-cv-5395-PJH, 22-cv-5396-PJH, 22-cv-5397-PJH, 22-cv-5398-PJH, 22-cv-5399-PJH, 22-cv-5400-PJH, 22-cv-5404-PJH, 22-cv-5405-PJH, 22-cv-5430-PJH, 22-cv-5431-PJH, 22-cv-5459-PJH, 22-cv-5460-PJH, 22-cv-5461-PJH, 22-cv-5462-PJH, 22-cv-5464-PJH, 22-cv-5465-PJH, 22-cv-5483-PJH, 22-cv-5484-PJH, 22-cv-5487-PJH, and 22-cv-5488-PJH.

The complaints asserted nearly identical claims against numerous state and federal judges and county clerks. Bonilla sought relief concerning his underlying conviction or the way other state and federal cases had been handled. The order also states that he had a pending federal petition challenging his custody, with appointed counsel, and was represented by counsel in state-court proceedings concerning his custody.

Filing-Fee Restriction

Bonilla sought, or might have sought, permission to proceed without paying the filing fees. The court held that 28 U.S.C. § 1915(g) barred him from proceeding without those fees unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court cited earlier proceedings stating that he had been disqualified from proceeding without fees. It found that the allegations in these complaints did not show the required immediate danger.

Other Legal Bars

The court further stated that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under several decisions: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not separately explain how each cited rule applied to each complaint.

Ruling and Case Closure

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The order also concluded that the repetitive and allegedly frivolous filings did not create a reasonable question about the judge's impartiality, so the order did not identify a basis for recusal. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in the closed cases. The order did not state that the court reached the underlying merits of the civil-rights claims.