Bonilla v. Chhabria
- Phyllis Hamilton
- 4:24-cv-09260
- U.S. District Court · Northern District of California
- 3
Bonilla v. Simmons: Judge Hamilton dismissed the prisoner’s multiple civil-rights cases with prejudice because he could not proceed without fees and his lawsuits were barred.
Steven Wayne Bonilla’s multiple self-represented civil-rights lawsuits were dismissed with prejudice, and the cases were closed. The order also affects any future documents he submits in those closed cases, which the clerk was directed to return without filing.
What happened
In Steven Wayne Bonilla v. Judge Kelly V. Simmons et al., Bonilla, a condemned state prisoner representing himself, filed many nearly identical civil-rights lawsuits against federal and state judges and other officials. He challenged his conviction and how his other cases had been handled.
The court ruled that Bonilla could not proceed without paying filing fees because he did not show that he faced imminent danger of serious physical injury when he filed. The court also said that, even if he could proceed without fees, the lawsuits would be barred by other legal rules.
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. Chhabria · No. 4:24-cv-09260
- Phyllis Hamilton
- Jan. 6, 2025
Background
Steven Wayne 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 government officials. The opinion lists numerous related case numbers, including 24-cv-8847-PJH, 24-cv-8857-PJH, 24-cv-9025-PJH, and others.
The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the handling of his other cases in state and federal court. The opinion also states that he had a pending federal petition challenging his custody with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
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 such danger. The opinion also cites prior proceedings stating that Bonilla had been disqualified from proceeding without paying fees under that statute.
Other barriers and disposition
The court 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 separate claim-by-claim analyses of those doctrines. It concludes that the cases were dismissed with prejudice.
The court also rejected the suggestion that the assigned 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. The clerk was further directed to return, without filing, any additional documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.