Bonilla v. Humboldt County Superior Court, its Judges and Court Clerk's Office
- Phyllis Hamilton
- 4:24-cv-03514
- U.S. District Court · Northern District of California
- 3
Bonilla v. Chhabria: Judge Hamilton dismissed the cases with prejudice because Bonilla was not in imminent danger and the lawsuits were barred by cited legal rules.
Steven Wayne Bonilla’s multiple lawsuits were dismissed with prejudice. The named defendants included Judge Vince Chhabria and other state courts and federal judges. The clerk was directed to close the cases, terminate pending motions, and return future submissions in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria et al., Bonilla filed multiple nearly identical civil-rights lawsuits without a lawyer. He named state courts and federal judges as defendants and sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla had been barred from proceeding without paying filing fees unless he showed that he faced an immediate serious physical danger when he filed. The court found that his allegations did not show such danger. It also said that, even if he could proceed without paying, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed all the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Humboldt County Superior Court, its Judges and Court Clerk's Office · No. 4:24-cv-03514
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order states that he is a condemned prisoner with a pending federal petition challenging his custody and that he is represented by counsel in state-court proceedings concerning that petition. The complaints were nearly identical. They named various state courts and federal judges and sought relief related to Bonilla’s underlying conviction or the way state and federal courts handled his other cases.
Filing-fee status
The court explained that Bonilla had been disqualified from proceeding in forma pauperis, meaning without paying the filing fee in advance, under the “three strikes” provision of 28 U.S.C. § 1915(g). That provision allows a disqualified prisoner to proceed without prepaying the fee only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show that he faced such danger. Accordingly, he could not proceed without prepaying the fee.
Other barriers identified by the court
The court further stated that, even if an application to proceed without prepaying the filing fee 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 order did not decide the underlying legal claims on their merits; it identified these procedural and other legal barriers as additional reasons the cases could not proceed.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The order directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The order additionally stated that the repetitive and allegedly frivolous filings did not provide a basis to question the undersigned judge’s impartiality.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.