Bonilla v. Mendocino County Superior Court
- Phyllis Hamilton
- 4:24-cv-03516
- 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 exception and citing several legal bars.
Steven Wayne Bonilla and the defendants named in his multiple complaints, including various state courts and federal judges. The order closed all identified cases and terminated their pending motions.
What happened
Steven Wayne Bonilla v. Judge Vince Chhabria et. al. involved nearly identical complaints filed without a lawyer under a federal civil-rights law. Bonilla, a state prisoner, named various state courts and federal judges and sought relief concerning his conviction or the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fee unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not make that showing. The court also said that, even if Bonilla were allowed to proceed without paying the fee, the lawsuits were barred by several legal rules identified in earlier decisions.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future submissions without filing them. Judge Phyllis J. Hamilton also found that the repetitive filings did not provide a reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Mendocino County Superior Court · No. 4:24-cv-03516
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal law that allows claims against state officials for violating federal rights. He filed the complaints without a lawyer. The complaints were nearly identical, named various state courts and federal judges as defendants, and sought relief related to his underlying conviction or the handling of his other cases. The order also states that Bonilla had a pending federal case concerning his imprisonment and was represented by counsel in state-court proceedings concerning that matter.
Filing-fee restriction
The court addressed Bonilla’s apparent requests to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying the fee only if he shows that he was in immediate danger of serious physical injury when he filed the complaint. Citing two earlier proceedings, the court found that Bonilla was disqualified from proceeding without paying the fee and that his allegations did not show the required danger at filing.
Other stated barriers
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under principles identified through Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not analyze the underlying civil-rights claims on their merits.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Impartiality issue
The order also addressed the fact that Bonilla named the judge who issued the order as a defendant in one case. The court concluded that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to decide assigned cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.