Bonilla v. Chhabria
- Phyllis Hamilton
- 4:24-cv-08852
- U.S. District Court · Northern District of California
- 3
In Bonilla v. U.S. District Court San Francisco, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying and the lawsuits were independently barred.
Steven Wayne Bonilla and the multiple related civil-rights cases he filed; the order also terminated pending motions and directed the clerk to reject further filings in those closed cases.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights complaints against federal and state judges and other officials. He challenged his conviction and how other cases had been handled.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed an immediate risk of serious physical injury, which his complaints did not show. The court also said the lawsuits would be barred on other legal grounds even if that fee waiver were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was ordered to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Chhabria · No. 4:24-cv-08852
- Phyllis Hamilton
- Dec. 16, 2024
Background
Bonilla, a state prisoner sentenced to death, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against state officials. The complaints presented nearly identical claims and named various federal and state judges and other officials. They sought relief concerning Bonilla’s underlying conviction and the handling of his other cases.
The order states that Bonilla had a pending federal petition challenging his conviction, with appointed counsel, and was represented by counsel in state proceedings challenging his conviction. The court also noted Bonilla’s history of filing similar cases.
Reasons for dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaint. The allegations did not show such danger, so he could not proceed under that fee-waiver procedure.
The court further stated that, even if a fee-waiver application were granted, the lawsuits would be barred under several legal doctrines and authorities, including rules concerning challenges to criminal convictions, ongoing state proceedings, claims against federal judges, and challenges to federal court proceedings. The order therefore dismissed the cases with prejudice. It did not decide the underlying correctness of Bonilla’s conviction or the other court proceedings on their merits.
Other rulings and disposition
The court rejected the suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The order noted that Bonilla named the judge as a defendant in one of the cases, but concluded that the filings did not provide a legitimate reason for recusal.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.