Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:24-cv-03511
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Vince Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also ended the pending motions, closed the cases, and directed the clerk to return later submissions in those cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria et al., Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits without a lawyer against various state courts and federal judges. He sought relief concerning his conviction and the handling of other court cases.
Bonilla was barred from proceeding without paying the filing fee unless he showed that he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. The court also said that, even if he could proceed without paying the fee, the lawsuits were barred by legal doctrines identified in the order.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:24-cv-03511
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical and named various state courts and federal judges as defendants. Bonilla sought relief concerning his underlying conviction and the way other state and federal cases had been handled.
Filing-fee status
The court explained that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the required filing fee, under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without the fee only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show imminent danger, so he could not proceed in forma pauperis.
Other barriers identified by the court
The court further stated that, even if an application to proceed in forma pauperis were granted, the lawsuits would be barred under the legal doctrines and authorities identified in the order, including Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying validity of Bonilla's conviction or the merits of his allegations against the defendants.
Ruling and case administration
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court also rejected the suggestion that the judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings, including because Bonilla named the judge as a defendant in one case without presenting a basis for recusal. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Disposition
The multiple cases were dismissed with prejudice. The pending motions were terminated, the cases were closed, and future documents submitted in those cases were to be returned without filing.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.