Bonilla
- Vince Chhabria
- 3:19-cv-06680
- U.S. District Court · Northern District of California
- 2
In Bonilla, Judge Chhabria dismissed with prejudice a prisoner’s mandamus petition challenging vexatious-litigant statutes and state criminal proceedings.
Steven Wayne Bonilla, a state inmate proceeding without a lawyer; the order also concerns his pending state criminal proceedings and challenges to California and federal filing-fee restrictions.
What happened
In Bonilla, state inmate Steven Wayne Bonilla filed a document without a lawyer challenging California and federal rules that can limit fee-free lawsuits by people who have filed repeated frivolous cases. The court treated the document as a petition asking for a court order requiring another court or official to act.
The court said both statutes had survived constitutional challenges. It also said Bonilla’s complaints about his state criminal proceedings belonged in his separate pending habeas case, not in this petition, and that this court lacked authority to order a state court or another federal district court to act.
Judge Vince Chhabria dismissed the petition with prejudice, ordered the case closed, ended all pending motions, and directed the Clerk not to file further documents Bonilla submitted after closure.
The detailed version
- Bonilla · No. 3:19-cv-06680
- Vince Chhabria
- Nov. 25, 2019
Background
Steven Wayne Bonilla, identified as a state inmate, filed a document without a lawyer titled “In re: to the matter of Steven Wayne Bonilla being declared a vexatious litigant.” The Clerk treated it as a petition for a writ of mandamus, which is a request for a court order compelling a government body or official to take a particular action.
Bonilla argued that California Code of Civil Procedure section 391 and 28 U.S.C. § 1915(g) were unconstitutional. The opinion explains that these provisions can prevent a litigant who has filed a specified number of frivolous lawsuits from proceeding without paying filing fees.
Court’s Analysis
The court stated that California section 391 had repeatedly been held constitutional by state and federal courts. It also stated that § 1915(g) did not violate prisoners’ Fifth Amendment rights to due process or equal protection because the rule had a rational basis, did not infringe a fundamental right, and did not discriminate against a protected class. The court further stated that § 1915(g) did not violate separation of powers.
The court said the main point of Bonilla’s petition was his dissatisfaction with the outcome of his state criminal proceedings. It directed that any claim concerning those proceedings be raised in Bonilla’s pending habeas case, identified in the opinion as Bonilla v. Ayers, Jr., 08-0471 YGR, rather than in a separate mandamus petition.
The court also held that it lacked authority to issue orders to a state court or to another federal district court. In addition, it determined that there was no basis to question the undersigned judge’s impartiality.
Disposition
Judge Vince Chhabria dismissed the petition with prejudice. The Clerk was ordered to close the case, terminate all pending motions, and return without filing any further documents Bonilla submitted after the case was closed.
Classification Note
The order includes a merits determination rejecting Bonilla’s constitutional challenges to the statutes, but it also disposes of his requests concerning the state criminal proceedings and other courts on threshold authority and case-routing grounds. For that reason, the classification is mixed.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.