Bonilla v. Chhabria
- Phyllis Hamilton
- 4:24-cv-03209
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple cases with prejudice because IFP restrictions and other legal bars prevented Bonilla’s civil-rights suits.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; all pending motions were terminated, the cases were closed, and further documents submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. Chhabria, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases under 42 U.S.C. § 1983. He named various state courts and federal judges and sought relief concerning his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by other legal rules. It dismissed the cases with prejudice, terminated all pending motions, and closed the cases.
Judge Phyllis J. Hamilton also rejected any suggestion that her impartiality could reasonably be questioned because of Bonilla’s repetitive filings. The clerk was directed to return, without filing, any further documents Bonilla submits in these closed cases.
The detailed version
- Bonilla v. Chhabria · No. 4:24-cv-03209
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints presented nearly identical claims and named various state courts and federal judges as defendants. Bonilla sought relief related to his underlying conviction or the way his other state and federal cases had been handled. The court also noted that he had a pending federal habeas case and was represented by counsel in state-court habeas proceedings.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under 28 U.S.C. § 1915(g). He therefore could proceed without paying only if he showed that he was under imminent danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger.
Other Bars and Disposition
The court further stated that, even if Bonilla’s applications to proceed without paying were granted, the lawsuits would be barred under one or more legal authorities the court cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court therefore dismissed the cases with prejudice. It directed the clerk to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submits in the closed cases.
Impartiality
The court addressed the fact that Bonilla named the undersigned judge as a defendant in one of the cases. Judge Phyllis J. Hamilton concluded that her impartiality could not reasonably be questioned merely because the filings were repetitive and frivolous. The opinion also noted Bonilla’s extensive history of filing similar cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.