Bonilla v. California Supreme Court

Background

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

Filing-fee status

The court stated that Bonilla had previously been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore concluded that Bonilla could not proceed without prepaying the fees.

Other grounds for dismissal

The court further stated that, even if Bonilla’s applications to proceed without prepaying fees were 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 opinion did not decide the underlying validity of Bonilla’s conviction or the merits of his allegations against the judges.

Disposition

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was ordered 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 concluded that the repetitive and frivolous nature of the filings did not provide a basis to question the judge’s impartiality. A footnote states that Bonilla named the judge as a defendant in one case but presented no legitimate reason for recusal.