Bonilla v. Contra Costa County Court Clerk's Office

Background

Steven Wayne Bonilla, described by the court as a condemned state prisoner, filed multiple lawsuits without a lawyer under 42 U.S.C. § 1983, the federal law that allows claims against state actors for violating federal rights. The cases named numerous county clerks and federal judges as defendants. The complaints were nearly identical and sought relief concerning Bonilla’s underlying conviction and the handling of his other cases in state and federal court.

The opinion identifies a pending federal petition concerning Bonilla’s conviction, in which he had appointed counsel, and state habeas proceedings in which he was represented by counsel. The opinion lists multiple related case numbers, including 22-cv-5562-PJH, 22-cv-5595-PJH, 22-cv-5596-PJH, 22-cv-5597-PJH, 22-cv-5598-PJH, 22-cv-5599-PJH, 22-cv-5600-PJH, 22-cv-5601-PJH, 22-cv-5603-PJH, 22-cv-5604-PJH, 22-cv-5605-PJH, 22-cv-5606-PJH, 22-cv-5607-PJH, 22-cv-5608-PJH, 22-cv-5610-PJH, 22-cv-5611-PJH, 22-cv-5612-PJH, 22-cv-5615-PJH, 22-cv-5618-PJH, 22-cv-5619-PJH, 22-cv-5621-PJH, 22-cv-5818-PJH, 22-cv-5819-PJH, 22-cv-5968-PJH, and 22-cv-6056-PJH.

Court’s reasoning

The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the fee.

The court added 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, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately explain which rule applied to which claim or case.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It cited the rule that, absent legitimate reasons 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, and to return without filing any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order.

Classification note

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