Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:24-cv-03537
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed Bonilla’s multiple civil-rights cases with prejudice after finding no imminent danger and identifying additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The cases named various state courts and federal judges, and the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria et al., Bonilla, a condemned state prisoner, filed multiple nearly identical civil-rights cases without a lawyer. He challenged his conviction and the handling of his other cases, naming various state courts and federal judges.
Bonilla could not proceed without paying the filing fee because he had previously been barred from that status unless he showed imminent danger of serious physical injury. The court found that his complaints did not show such danger. The court also said the lawsuits would be barred for other legal reasons even if he could proceed without paying.
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 future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:24-cv-03537
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal civil-rights statute. The opinion identifies him as a state prisoner and a condemned prisoner. It also says he had a pending federal petition challenging his custody and was represented by counsel in state-court proceedings concerning that petition.
The complaints were nearly identical. Bonilla named various state courts and federal judges as defendants and sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
Filing-fee status and legal bars
The court addressed Bonilla’s requests, or possible requests, to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant prior filing history may proceed without paying only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court said Bonilla had been disqualified from proceeding without paying under that provision and that these complaints did not show imminent danger.
The court further stated that, even if an application to proceed without paying 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 opinion did not decide the validity of Bonilla’s underlying conviction or reach the merits of the claims about how his other cases were handled.
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. The court also stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the undersigned judge’s impartiality.
Classification
This is a procedural order because the court disposed of the cases based on the prisoner filing-fee restriction and other legal bars without deciding the underlying civil-rights claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.