Bonilla v. Goodfellow
- Vince Chhabria
- 3:19-cv-07712
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Goodfellow, Judge Chhabria dismissed Bonilla’s civil-rights case with prejudice because he did not show imminent danger and the lawsuit was barred by Heck.
Steven Wayne Bonilla’s Section 1983 lawsuit was dismissed with prejudice, affecting his claims against the state judges and the Alameda County District Attorney’s Office named in the complaint.
What happened
Bonilla v. Goodfellow concerned Steven Wayne Bonilla, a state inmate representing himself in a civil-rights lawsuit under a federal law known as Section 1983. He sued state judges and the Alameda County District Attorney’s Office.
Bonilla had previously been barred from proceeding without paying the filing fee unless he showed that he faced an immediate risk of serious physical injury when he filed the complaint. The court found that his allegations did not show that kind of danger. The court also said that, even if Bonilla’s request to proceed without paying the fee were granted, a rule from Heck v. Humphrey would bar the lawsuit.
Judge Vince Chhabria dismissed the case with prejudice and ordered the Clerk to close it. The Clerk was also ordered to return, without filing, any further documents Bonilla submitted after the case closed.
The detailed version
- Bonilla v. Goodfellow · No. 3:19-cv-07712
- Vince Chhabria
- Nov. 29, 2019
Background
Steven Wayne Bonilla, a state inmate proceeding without a lawyer, filed a civil action under 42 U.S.C. § 1983 against state judges and the Alameda County District Attorney’s Office. He sought permission to proceed without paying the filing fee, a status commonly called in forma pauperis, or IFP.
Bonilla had previously been disqualified from proceeding IFP under 28 U.S.C. § 1915(g). That statute allows a disqualified prisoner to proceed without paying only if, when the complaint is filed, he is under imminent danger of serious physical injury.
Analysis
The court concluded that the complaint’s allegations did not show that Bonilla was in imminent danger when he filed it. As a result, he could not proceed IFP.
The court added that, even if Bonilla’s IFP application were granted, the lawsuit would be barred under Heck v. Humphrey, 512 U.S. 477 (1994). The opinion did not provide further explanation of how Heck applied to the claims.
The court also stated that this was not a case in which the judge’s impartiality could reasonably be questioned.
Disposition
Judge Vince Chhabria dismissed the case with prejudice. 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.