Bonilla v. Sonoma County Superior Court

Background

Steven Wayne Bonilla, a state prisoner and condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The complaints named various federal and state judges and state courts as defendants. The court stated that Bonilla presented nearly identical claims in the cases and sought relief concerning his underlying conviction or the handling of his other state and federal court cases.

The opinion also noted that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state habeas proceedings. The opinion identified the matters as a group of cases, including Case Nos. 23-cv-6555-PJH, 24-cv-0018-PJH, 24-cv-0020-PJH, 24-cv-0021-PJH, 24-cv-0022-PJH, 24-cv-0029-PJH, 24-cv-0031-PJH, 24-cv-0367-PJH, 24-cv-0369-PJH, 24-cv-0381-PJH, 24-cv-0382-PJH, 24-cv-0383-PJH, 24-cv-0422-PJH, 24-cv-0423-PJH, 24-cv-0446-PJH, 24-cv-0453-PJH, 24-cv-0454-PJH, 24-cv-0455-PJH, 24-cv-0456-PJH, 24-cv-0458-PJH, 24-cv-0459-PJH, 24-cv-0460-PJH, and 24-cv-0461-PJH.

Filing-fee restriction

To the extent Bonilla sought permission to proceed without paying filing fees, the court applied 28 U.S.C. § 1915(g). That provision disqualifies a prisoner from proceeding without fees after qualifying prior filings unless the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified from proceeding without fees under that provision.

The court found that the allegations in these complaints did not show that Bonilla was in imminent danger at the time of filing. It therefore concluded that he could not proceed without paying the filing fees.

Other grounds for dismissal

The court further ruled that, even if an application to proceed without fees were granted, the lawsuits would be barred under the legal doctrines and authorities identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not resolve the underlying challenges to Bonilla’s conviction or decide whether the alleged conduct by the courts and judges was legally valid. Instead, it dismissed the cases on filing-fee and other threshold grounds.

Recusal issue and disposition

Bonilla named Judge Hamilton as a defendant in one of the cases, but the court stated that he presented no legitimate basis for questioning her impartiality. The court also stated that the repetitive and frivolous nature of the filings did not create a reasonable basis for recusal.

Judge Hamilton ordered that the cases be dismissed with prejudice. She directed the clerk to terminate all pending motions and close the cases, and directed the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.