Bonilla v. San Benito County Superior Court

Background

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

Filing-fee status

Bonilla sought, or potentially sought, permission to proceed without paying the filing fees. The court said he had already been disqualified from that status under 28 U.S.C. § 1915(g), unless 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 concluded that Bonilla could not proceed without paying the filing fees.

Other grounds for dismissal

The court further stated that, even if Bonilla’s request to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines or authorities discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those grounds.

Ruling and case closure

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The court additionally rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings, and stated that a judge generally has a duty to decide assigned cases absent legitimate reasons for recusal.