Bonilla v. Freeman
- Vince Chhabria
- 3:19-cv-05693
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Freeman, Judge Chhabria dismissed Steven Bonilla’s lawsuit with prejudice because he did not show imminent danger and the lawsuit was barred under Heck.
Steven Wayne Bonilla and the defendant United States district judges named in the complaint. The clerk’s instructions also affect any further documents Bonilla submits in this closed case.
What happened
In Bonilla v. Freeman, Steven Wayne Bonilla, a state inmate representing himself, sued several United States district judges under a federal civil-rights law.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced imminent danger of serious physical injury when he filed the complaint. The court found that his allegations did not show such danger.
Judge Vince Chhabria dismissed the case with prejudice, also ruling that the lawsuit would be barred under Heck v. Humphrey even if Bonilla had been allowed to proceed without paying filing fees. The clerk was ordered to close the case and return later documents without filing them.
The detailed version
- Bonilla v. Freeman · No. 3:19-cv-05693
- Vince Chhabria
- Sept. 25, 2019
Background
Steven Wayne Bonilla, identified as a state inmate, filed a civil action without a lawyer under 42 U.S.C. § 1983. He sued Beth Labson Freeman, Jeffrey S. White, Vince Chhabria, Howard Lloyd, Claudia Wilken, Yvonne Gonzalez Rogers, and Richard Seeborg, whom the opinion identifies as United States district judges.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the filing fee in advance, under 28 U.S.C. § 1915(g). That exception would have allowed him to proceed only if he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show imminent danger at that time.
Heck ruling
The court further stated that, even if Bonilla’s application to proceed without paying the filing fee had been granted, the lawsuit would be barred under Heck v. Humphrey, 512 U.S. 477 (1994). The opinion does not explain the underlying allegations or the specific reason Heck applied beyond that conclusion.
Disposition
The court dismissed the case with prejudice. It also stated that the impartiality of the judge who issued the order could not reasonably be questioned. The clerk was directed to close the case and return, without filing, any further documents Bonilla submitted after the case was closed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.