Bonilla v. Chhabria
- Phyllis Hamilton
- 4:24-cv-06655
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Freeman, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying filing and claim barriers.
Steven Wayne Bonilla’s ten related civil-rights cases were dismissed with prejudice, and he could not proceed in them without paying the filing fee because the court found no imminent danger of serious physical injury.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights lawsuits against various federal and state judges. He challenged his conviction or the handling of his other court cases and represented himself in these lawsuits.
The court found that Bonilla could not proceed without paying the filing fee 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 his fee-waiver applications were granted, the lawsuits would be barred by several legal rules.
The court dismissed the cases with prejudice, terminated all pending motions, and closed the cases. Judge Phyllis J. Hamilton also rejected any claim that her impartiality could reasonably be questioned based on the filings.
The detailed version
- Bonilla v. Chhabria · No. 4:24-cv-06655
- Phyllis Hamilton
- Sept. 26, 2024
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical and named various federal and state judges as defendants. The opinion says Bonilla sought relief concerning his underlying conviction or the way other state and federal court cases had been handled. It also notes that he had appointed counsel in a pending federal petition challenging his custody and was represented by counsel in state-court proceedings.
Filing-fee status
Bonilla sought, or potentially sought, permission to proceed without paying the filing fee. The court held that 28 U.S.C. § 1915(g) disqualified him from proceeding this way 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 such danger. As a result, he could not proceed without paying the filing fee.
Other barriers identified by the court
The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under several legal doctrines and statutes, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, restrictions on certain claims against federal courts, and judicial immunity. The opinion cited Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court, but did not separately analyze each doctrine in detail.
Ruling
The court dismissed all of the identified cases with prejudice. “With prejudice” means the dismissal bars refiling the dismissed cases. 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.
The court also addressed judicial impartiality, stating that the repetitive and allegedly frivolous nature of the filings did not create a reasonable basis to question the undersigned judge’s impartiality. Judge Phyllis J. Hamilton signed the order.
Classification basis
This is a procedural order. The court disposed of the cases based on filing-fee eligibility and threshold legal barriers rather than deciding the underlying challenges to Bonilla’s conviction or the handling of his other cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.