Bonilla v. Humboldt County Superior Court

Background

Steven Wayne Bonilla, identified in the opinion as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. He named various state courts and federal judges as defendants. The complaints were nearly identical and sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.

The opinion states that Bonilla had a pending federal habeas petition in the court with appointed counsel and was represented by counsel in state habeas proceedings. The court also noted his history of filing similar cases.

Filing-fee status and legal barriers

To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he faced imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.

The court further stated that, even if Bonilla had been allowed to proceed without paying fees, the lawsuits would be barred under the legal rules and decisions it cited, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not resolve the underlying allegations on their merits.

Ruling

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.

The court additionally addressed impartiality. It concluded that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. Judge Phyllis J. Hamilton cited the principle that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.