Bonilla v. Santa Cruz Superior Court

Background

Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. He is a condemned prisoner and has a pending federal petition challenging his detention, in which he has appointed counsel. The opinion also states that he is represented by counsel in state-court habeas proceedings.

Bonilla named various federal and state judges and state courts as defendants. The complaints sought relief concerning his underlying conviction and the way his other cases had been handled by state and federal courts.

Filing-fee restriction

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

The court found that the allegations did not show that Bonilla faced such a danger at the time of filing. He therefore could not proceed without paying the filing fee.

Additional grounds for dismissal

The court stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would still be barred under the legal principles identified 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.

Disposition

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

The court additionally rejected any suggestion that Judge Hamilton's impartiality could reasonably be questioned because of Bonilla's repetitive and allegedly frivolous filings. The opinion states that Bonilla named Judge Hamilton as a defendant in one of the cases but presented no legitimate reason for recusal. The court also noted Bonilla's extensive history of filing similar cases.

Classification basis

This is a procedural order. The court dismissed the cases based on Bonilla's inability to proceed without paying the filing fee and on threshold legal bars, without deciding the underlying claims about his conviction or the handling of his cases.