Bonilla v. Chhabria
- Phyllis Hamilton
- 4:24-cv-09282
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Simmons, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla showed no imminent danger and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The named federal and state judges and other officials were defendants in those cases, and the court terminated the pending motions and closed the cases.
What happened
Steven Wayne Bonilla v. Judge Kelly V. Simmons et al. involved multiple nearly identical civil-rights complaints filed by Bonilla, a condemned state prisoner representing himself. He sued various federal and state judges and other officials, seeking relief related to his conviction and the handling of his court cases.
The court found that Bonilla could not proceed without paying filing fees because he had previously been disqualified from that status and his complaints did not show imminent danger of serious physical injury when filed. The court also said the lawsuits would be barred even if that payment status were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Chhabria · No. 4:24-cv-09282
- Phyllis Hamilton
- Jan. 6, 2025
Background
The order covers multiple cases listed in the caption. Steven Wayne Bonilla, a state prisoner sentenced to death, filed the complaints without a lawyer under 42 U.S.C. § 1983. The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the way his state and federal cases had been handled.
The court noted that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel. It also noted that he was represented by counsel in state-court proceedings concerning his custody.
Filing-fee status and claim bars
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 faced imminent danger of serious physical injury when he filed the complaints. The court relied on Bonilla's prior proceedings and found that the allegations in these complaints did not show such danger.
The court further held that, even if Bonilla had been allowed to proceed without paying filing fees, the lawsuits would be barred under the authorities it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate merits analysis of the underlying claims.
Disposition
The court dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in the closed cases.
Bonilla named the presiding judge as a defendant in two of the cases. The court stated that the repetitive and frivolous nature of the filings did not provide a basis to reasonably question the judge's impartiality. Judge Phyllis J. Hamilton signed the order on January 6, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.