Bonilla v. Chhabria

Background

Steven Wayne Bonilla, described 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. They named various federal judges, state judges, and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the handling of his other state and federal cases.

The order concerns the case numbers listed in the caption, including 25-cv-6353-PJH, 25-cv-6847-PJH, 25-cv-6849-PJH, and numerous related cases. The court also noted that Bonilla had a pending federal petition challenging his conviction in the same district with appointed counsel and was represented by counsel in state-court proceedings.

Filing-fee status and legal bars

The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding in forma pauperis—that is, without prepaying filing fees—unless he was under imminent danger of serious physical injury when he filed his complaints. The court found that the allegations did not show imminent danger at the relevant time, so Bonilla could not proceed under that exception.

The court further stated that, even if an application to proceed without prepaying fees were granted, the lawsuits would be barred under the rules or doctrines identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The order did not provide a separate merits determination for each complaint.

Ruling

The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.

The order separately addressed whether the judge should recuse herself, meaning step aside because impartiality might reasonably be questioned. The court concluded that the repetitive and allegedly frivolous nature of the filings did not create that basis for recusal. It noted that Bonilla had named the judge as a defendant in three cases but had made no specific allegations against her in those cases.

The court also noted Bonilla’s extensive history of filing similar frivolous cases, including the number of cases associated with the undersigned judge and three other judges.