Bonilla v. Santa Clara 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 complaints were nearly identical. They named various federal and state judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his other cases.

The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court, where he had appointed counsel, and that he was represented by counsel in state-court proceedings. Those proceedings were separate from the cases addressed in this order.

Court’s Analysis

The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner disqualified from proceeding without paying may do so only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court concluded that Bonilla’s allegations did not show such danger.

The court further held that, even if an application to proceed without paying had been 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 analyze each bar separately; it states that those authorities independently supported dismissal.

The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s repeated and frivolous filings. The opinion states that Bonilla named Judge Hamilton as a defendant in three of the cases but made no specific allegations against her.

Disposition

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