Bonilla v. Superior Court, County of San Francisco

Background

Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple nearly identical complaints under 42 U.S.C. § 1983, a federal law allowing civil-rights claims against state actors. The complaints named various state courts and federal judges as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases.

The opinion states that Bonilla had a pending federal petition challenging his custody, with appointed counsel, and was also represented by counsel in state-court proceedings concerning his custody. The opinion also notes Bonilla's history of filing similar cases.

Court's reasoning

The court addressed Bonilla's request, or possible request, to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without paying fees may do so 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 Bonilla's allegations did not show such danger. The court therefore ruled that he could not proceed without paying the fees.

The court further ruled that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not provide a separate claim-by-claim analysis of each case.

The court also stated that the repetitive and allegedly frivolous filings did not create a reasonable basis to question the impartiality of the judge assigned to the cases.

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 the closed cases.