Bonilla v. Santa Clara County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints named various federal and state judges as defendants. They were nearly identical and sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled. The opinion also states that Bonilla had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that challenge.

Reasons for dismissal

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

The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under several legal doctrines. The cited doctrines included rules limiting civil-rights claims that would undermine a conviction, rules requiring federal courts to avoid interfering with certain ongoing state proceedings, and rules concerning challenges to the actions of federal courts. The opinion did not separately analyze each doctrine as to each case.

Disposition

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. The court also rejected recusal concerns, explaining that the repetitive and frivolous nature of the filings did not provide a basis to question the presiding judge’s impartiality. Judge Phyllis J. Hamilton signed the order.