Bonilla v. Sacramento County Court Clerk's Office

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were filed in the related cases listed in the order. Bonilla named numerous county clerks and federal judges as defendants and presented nearly identical claims. The order says he sought relief concerning his underlying conviction or the way his other state and federal court cases had been handled.

The court also noted that Bonilla had a pending federal petition challenging his custody in that court with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee waiver and legal barriers

The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed the complaint. The court found that the allegations in these cases did not make that showing. As a result, Bonilla could not proceed without paying the filing fees.

The court further stated that, even if an application to waive the filing fees were granted, the lawsuits would be barred under the principles identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not separately explain which cited rule applied to which case or claim.

Recusal and disposition

The court rejected any suggestion that Judge Phyllis J. Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide cases assigned to that judge.

The court dismissed the cases with prejudice. It directed 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.