Bonilla v. San Francisco County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints presented nearly identical claims and named various federal judges and federal and state courts as defendants. Bonilla sought relief concerning his underlying conviction and the way his other state and federal cases had been handled. The order also noted that he had a pending federal petition concerning his imprisonment in the same court, with appointed counsel.

Filing-Fee Ruling

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

Other Grounds for Dismissal

The court further ruled that, even if an application to proceed without paying the fee 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, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate analysis explaining which doctrine applied to which case or claim.

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.

Impartiality and Recusal

The order also stated that these were not cases in which the undersigned judge’s impartiality might reasonably be questioned because of the repetitive and frivolous nature of the filings. A footnote noted that Bonilla named the undersigned judge as a defendant in one case but presented no legitimate reason for recusal in the portion provided.