Bonilla v. San Mateo County Superior Court
- Phyllis Hamilton
- 4:24-cv-03517
- U.S. District Court · Northern District of California
- 3
Bonilla v. Chhabria: Judge Hamilton dismissed Bonilla’s multiple civil-rights cases with prejudice because he could not proceed without paying and the suits were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the named state-court and federal-judge defendants were affected by the closure of those cases.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria et al., Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights cases against state courts and federal judges. He sought relief related to his conviction and how other cases had been handled.
The court said Bonilla had previously been barred from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury. The complaints did not show that danger. The court also said the lawsuits would be barred even if he were allowed to proceed without paying, citing rules that prevent certain challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. San Mateo County Superior Court · No. 4:24-cv-03517
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, a state prisoner facing a death sentence, filed multiple nearly identical complaints under 42 U.S.C. § 1983, the federal law that allows claims against state actors for certain violations of federal rights. He represented himself in these cases. The complaints named various state courts and federal judges as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other cases in state and federal court.
The order addressed multiple related cases, including Case Nos. 24-cv-3209-PJH, 24-cv-3212-PJH, 24-cv-3228-PJH, 24-cv-3238-PJH, 24-cv-3249-PJH, 24-cv-3342-PJH, 24-cv-3418-PJH, 24-cv-3419-PJH, 24-cv-3507-PJH, 24-cv-3509-PJH, 24-cv-3511-PJH, 24-cv-3514-PJH, 24-cv-3515-PJH, 24-cv-3516-PJH, 24-cv-3517-PJH, 24-cv-3533-PJH, 24-cv-3534-PJH, 24-cv-3537-PJH, 24-cv-3562-PJH, 24-cv-3563-PJH, 24-cv-3564-PJH, and 24-cv-3600-PJH.
Proceeding Without Paying the Filing Fee
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger. Accordingly, Bonilla could not proceed without paying the filing fee.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several authorities. These included rules concerning challenges to criminal convictions, federal interference with certain ongoing proceedings, and suits seeking to control or overturn actions by other courts. The order did not resolve the underlying claims in Bonilla’s favor or the defendants’ favor; it dismissed the cases based on these threshold and procedural grounds.
Recusal Issue
The court also addressed the fact that Bonilla named the assigned judge as a defendant in one of the cases. Judge Hamilton concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question her impartiality. The order stated that, absent legitimate reasons for recusal, a judge has a duty to hear assigned cases.
Disposition
Judge Phyllis J. Hamilton ordered that the cases be dismissed with prejudice. The clerk was directed to terminate all pending motions and close the cases, and 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.