Bonilla v. Alameda County District Attorney's Office
- Phyllis Hamilton
- 4:24-cv-03418
- U.S. District Court · Northern District of California
- 3
Bonilla v. Chhabria: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the claims were barred.
Steven Wayne Bonilla’s multiple pro se civil-rights cases and their pending motions were affected; the cases were closed and future submissions in them were to be returned without filing.
What happened
In Bonilla v. Judge Vince Chhabria et al., Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights cases under a federal statute allowing suits against government officials. He challenged his conviction and the handling of his other cases, naming various state courts and federal judges.
The court said Bonilla had previously been disqualified from proceeding without paying the filing fee unless he showed an immediate danger of serious physical injury. The complaints did not show that danger. The court also said the lawsuits would be barred even if he were allowed to proceed without paying, citing several legal doctrines and cases.
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. Alameda County District Attorney's Office · No. 4:24-cv-03418
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, described by the court as a state prisoner and a condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various state courts and federal judges as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other cases had been handled by state and federal courts. The court also noted that Bonilla had a pending federal habeas case and was represented by counsel in state-court habeas proceedings.
Filing-fee restriction
The court considered Bonilla’s ability to proceed in forma pauperis, meaning without paying the filing fee. It stated that he had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger. Bonilla therefore could not proceed without paying the filing fee.
Other stated barriers
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 does not separately analyze which specific doctrine applied to which individual case or claim. The court also described Bonilla as having an extensive history of filing similar cases.
Ruling
The court dismissed the cases with prejudice. It also rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.
Disposition
The multiple cases were dismissed with prejudice. The order did not decide the underlying validity of Bonilla’s conviction or otherwise reach the merits of his civil-rights claims; it relied on the filing-fee restriction and stated procedural and legal barriers to the suits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.