Bonilla v. San Benito County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, the federal civil-rights statute. The opinion lists numerous related case numbers, beginning with 23-cv-6555-PJH and including cases filed in 2024. Bonilla named various federal and state judges and state courts as defendants. He sought relief concerning his underlying conviction and the way his other state and federal cases had been handled.

The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings concerning that petition. Those proceedings are mentioned as background to the multiple civil-rights complaints.

Reasons for dismissal

The court held that Bonilla could not proceed without paying the required filing fees under the prisoner-litigation statute’s “three strikes” restriction, 28 U.S.C. § 1915(g), unless he showed that he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such imminent danger. The opinion therefore concluded that Bonilla could not proceed without paying the filing fees under that exception.

The court separately stated that, even if an application to proceed without paying fees had been granted, the lawsuits would be barred under rules and precedents concerning challenges to criminal convictions, interference with ongoing proceedings, and review of other courts’ decisions. The opinion cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court.

The court also addressed Bonilla’s naming of the presiding judge as a defendant in one of the cases. It found that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality and cited the general duty of a judge to handle assigned cases absent legitimate grounds for recusal.

Disposition

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 those closed cases.

Names and caption

The opinion text supplied here captions the lead case as “STEVEN WAYNE BONILLA v. DEL NORTE SUPERIOR COURT et al.” The supplied metadata instead names “Bonilla v. San Benito County Superior Court.” This summary follows the opinion’s caption and flags the discrepancy rather than resolving it by inference.