Bonilla v. Napa County Superior Court

Background

Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983, a federal statute allowing claims against state actors for certain constitutional violations. The order lists multiple related case numbers, including 24-cv-1206-PJH, 24-cv-1211-PJH, 24-cv-1486-PJH, 24-cv-1488-PJH, 24-cv-1490-PJH, 24-cv-1491-PJH, 24-cv-1492-PJH, 24-cv-1493-PJH, 24-cv-1494-PJH, 24-cv-1536-PJH, 24-cv-1565-PJH, 24-cv-1566-PJH, 24-cv-1567-PJH, 24-cv-1568-PJH, 24-cv-1569-PJH, 24-cv-1570-PJH, 24-cv-1571-PJH, 24-cv-1572-PJH, 24-cv-1574-PJH, 24-cv-1575-PJH, 24-cv-1689-PJH, 24-cv-1690-PJH, 24-cv-1709-PJH, 24-cv-1710-PJH, 24-cv-1711-PJH, and 24-cv-1854-PJH.

The order describes Bonilla as a state prisoner and says he was proceeding without a lawyer in these cases. He named various federal and state judges as defendants. His complaints presented nearly identical claims seeking relief concerning his underlying conviction or the handling of his other cases by state and federal courts.

Reasoning

The court addressed Bonilla’s possible requests to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated qualifying prior dismissals generally cannot proceed without paying the filing fee unless the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such imminent danger.

The court also stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under doctrines identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those doctrines.

The court further rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. The order noted that Bonilla named Judge Hamilton as a defendant in three of the cases. It also stated that Judge Hamilton was the fourth judge assigned cases filed by Bonilla and that she had issued 61 orders concerning 826 different cases since April 30, 2020; it stated that Bonilla had filed 962 other cases with three other judges since 2011.

Disposition

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