Bonilla v. Marin County Superior Court

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The cases named various state courts and federal judges as defendants. The complaints were nearly identical 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 imprisonment, in which he had appointed counsel, and that he was represented by counsel in state-court proceedings concerning his imprisonment.

Filing-fee restriction

The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger. As a result, Bonilla could not proceed without paying the filing fees.

Other legal barriers

The court further stated that, even if an application to proceed without paying the filing fees were granted, the lawsuits would be barred under the doctrines 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 barriers.

The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and allegedly frivolous filings. It noted that the judge had a duty to decide cases assigned to her 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 ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.