Bonilla v. Chhabria
- Phyllis Hamilton
- 4:25-cv-02538
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Lydia Villarreal, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his lawsuits were barred.
Steven Wayne Bonilla’s multiple § 1983 cases were dismissed with prejudice; the order also terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing them.
What happened
In Bonilla v. Judge Lydia Villarreal et al., Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple nearly identical civil-rights lawsuits under a federal civil-rights law. He named various federal and state judges and other officials and sought relief concerning his conviction or the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because he had been disqualified from proceeding without those fees, and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if his applications to proceed without paying fees were granted, the lawsuits would be barred by several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return without filing any further documents Bonilla submitted in them. The court also concluded that its impartiality could not reasonably be questioned because of Bonilla’s repetitive and frivolous filings.
The detailed version
- Bonilla v. Chhabria · No. 4:25-cv-02538
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The cases listed multiple docket numbers, including 25-cv-1979-PJH, 25-cv-1980-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 or the way his other cases had been handled by state and federal courts.
The opinion states that Bonilla had a pending federal petition challenging his imprisonment in the same court, with appointed counsel, and was also represented by counsel in state-court proceedings concerning that petition. Those proceedings were not the subject of the court’s ruling here.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. It therefore concluded that Bonilla could not proceed without paying the filing fees.
Other Barriers to the Lawsuits
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine’s application to each complaint.
The court also addressed whether the judge’s impartiality could reasonably be questioned because Bonilla had filed repetitive and allegedly frivolous cases. It concluded that these circumstances did not require the judge to step aside. The opinion states that the judge had been the fourth judge assigned to Bonilla’s cases and had issued 74 orders since April 30, 2020, involving 1,090 different cases.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. The order was signed by United States District Judge Phyllis J. Hamilton on March 27, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.