Bonilla v. San Francisco County Superior Court
Bonilla v. San Francisco County Superior Court, its Judges and Court Clerk's Office
- Phyllis Hamilton
- 4:24-cv-03342
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without filing fees and his claims were barred.
Steven Wayne Bonilla's multiple cases were dismissed with prejudice, his pending motions were terminated, and the cases were closed. The clerk was directed to return without filing any further documents he submitted in those closed cases.
What happened
In Bonilla v. Judge Vince Chhabria et al., Steven Wayne Bonilla, a state prisoner, filed multiple similar civil-rights lawsuits without a lawyer against state courts and federal judges. He sought relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because he was barred from proceeding without fees under the federal three-strikes rule, and his complaints did not show imminent danger of serious physical injury when filed. The court also stated that the lawsuits would be barred by several legal doctrines, including rules protecting ongoing proceedings and restricting challenges to convictions or court actions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases. The clerk was also directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. San Francisco County Superior Court · No. 4:24-cv-03342
- Phyllis Hamilton
- June 25, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal civil-rights statute. The complaints were filed without a lawyer and presented nearly identical claims. Bonilla named various state courts and federal judges as defendants. The opinion states that he sought relief concerning his underlying conviction or the way his other cases had been handled by state and federal courts. The opinion also states that Bonilla is a condemned prisoner with a pending federal habeas case and is represented by counsel in state-court habeas proceedings.
Proceeding Without Paying Filing Fees
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the time of filing.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying fees 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 provide a separate claim-by-claim analysis explaining which of those doctrines applied to each case.
Disposition
The court dismissed the cases with prejudice. It 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 court additionally concluded that the repetitive and allegedly frivolous filings did not create a reasonable basis to question Judge Hamilton's impartiality, even though Bonilla named her as a defendant in one of the cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.