Bonilla v. Santa Clara County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases presented nearly identical claims and named various federal and state judges and state courts as defendants. Bonilla sought relief concerning his underlying conviction or the way other state and federal court cases had been handled.

The order states that Bonilla also had a pending federal petition challenging his detention in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. Those related matters were mentioned as background to the multiple new cases.

Filing-fee restriction

The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). Under that statute, a prisoner subject to that restriction may proceed without paying the fees only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed.

The court found that the allegations did not show imminent danger at the time of filing. It therefore held that Bonilla could not proceed without paying the filing fees.

Other legal bars

The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal doctrines or precedents identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim explanation of how each cited bar applied.

Rulings and disposition

The court dismissed the cases with prejudice. The order also directed the clerk to terminate all pending motions and close the cases. It directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.

The order separately addressed recusal. Although Bonilla named Judge Hamilton as a defendant in one case, the court concluded that the repetitive and allegedly frivolous nature of the filings did not create a reasonable question about the judge’s impartiality. Judge Hamilton therefore did not recuse herself.

Classification

This is a procedural order because the court disposed of the cases based on the filing-fee restriction and threshold legal bars rather than deciding the underlying civil-rights claims on their merits.