Bonilla v. Contra Costa County Superior Court

Background

Steven Wayne Bonilla, whom the opinion identifies as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The complaints were nearly identical and named various federal and state judges as defendants. They sought relief concerning Bonilla’s underlying conviction or the way other state and federal court cases had been handled.

The opinion also states that Bonilla had a pending federal petition challenging his custody in the same district court with appointed counsel and was represented by counsel in state-court proceedings concerning such a petition.

Filing-fee status and other bars

The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees 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 imminent danger at the relevant time.

The court further stated that, even if an application to proceed without paying filing fees were 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 separately analyze which cited doctrine applied to which individual case.

Ruling

Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court also concluded that the repetitive and allegedly frivolous nature of the filings did not provide a basis for reasonably questioning the judge’s impartiality. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents submitted by Bonilla in the closed cases.

Classification

This is a procedural order because the court dismissed the cases based on filing-fee eligibility and threshold legal bars without deciding whether Bonilla’s underlying civil-rights claims were legally valid.