Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:24-cv-03238
- U.S. District Court · Northern District of California
- 3
Bonilla v. Chhabria: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the lawsuits faced legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The clerk was directed to close the cases, terminate pending motions, and return future documents submitted in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria et al., Bonilla, a condemned state prisoner filing without a lawyer, brought multiple nearly identical civil-rights lawsuits against state courts and federal judges. He challenged his conviction and how other state and federal cases had been handled.
The court ruled that Bonilla was barred from proceeding without paying the filing fees because his complaints did not show an immediate danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if he were allowed to proceed without paying, citing several legal doctrines and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:24-cv-03238
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The opinion identifies him as a condemned state prisoner who also had a pending federal petition challenging his detention and was represented by counsel in state court proceedings. The complaints were nearly identical. They named various state courts and federal judges and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed his complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fees.
Other Legal Bars
The court further held that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the legal doctrines and authorities identified as Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not decide the truth of Bonilla’s underlying claims.
Impartiality and Disposition
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion noted that Bonilla named the judge as a defendant in one case. The court dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return without filing any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.