Bonilla v. Monterey Superior Court
- Phyllis Hamilton
- 4:24-cv-03600
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla and the multiple cases covered by the order; the cases were closed, pending motions were terminated, and further documents submitted in them were to be returned without filing.
What happened
In Bonilla v. Chhabria, Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against various state courts and federal judges. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla could not proceed without prepaying filing fees because he had previously been barred from doing so unless he showed that he faced an immediate serious physical danger when he filed. The court found that his allegations did not show such danger. It also said that, even if he could proceed without prepaying fees, the lawsuits would be barred under several legal rules cited by the court.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submits in them.
The detailed version
- Bonilla v. Monterey Superior Court · No. 4:24-cv-03600
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple complaints while representing himself. The complaints were brought under 42 U.S.C. § 1983, a federal civil-rights law. The cases named various state courts and federal judges as defendants. The court said the complaints presented nearly identical claims concerning Bonilla’s underlying conviction or the way other state and federal cases had been handled. The order also noted that Bonilla had counsel in state-court habeas proceedings.
Filing-fee restriction
The court addressed Bonilla’s efforts to proceed without prepaying filing fees. It said he had been disqualified under 28 U.S.C. § 1915(g), which generally prevents a prisoner with the required history of dismissed cases from proceeding without prepaying fees unless the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court found that the allegations did not show imminent danger at the relevant time.
Additional grounds identified by the court
The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide separate claim-by-claim analysis of those authorities. It also described Bonilla as having an extensive history of filing similar cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submits in the closed cases.
The court separately rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The order states that Bonilla named Judge Hamilton as a defendant in one of the cases but did not present a legitimate reason for recusal. Judge Hamilton signed the order on June 25, 2024.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.