Bonilla v. Culver

Background

Steven Wayne Bonilla, a state prisoner who is condemned, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints presented nearly identical claims against various state courts and judges. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases. The opinion also notes that he had a pending federal petition challenging his imprisonment with appointed counsel and was represented by counsel in state-court proceedings.

Filing-Fee Status

The court explained that Bonilla had been disqualified from proceeding in forma pauperis, meaning without prepaying 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 complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without prepaying the filing fee.

Other Grounds for Dismissal

The court further stated that, even if an application to proceed without prepaying fees had been granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not provide separate analyses of how each cited decision applied to each complaint. The cases were dismissed with prejudice.

Recusal Request and Case Closure

A footnote states that Bonilla named Judge Hamilton as a defendant in one case, 23-cv-5965-PJH, and sought her recusal, meaning removal of the judge because of claimed impartiality concerns. The court denied that request, finding the arguments meritless in light of Bonilla’s numerous similar filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submits in those closed cases.