Bonilla v. Gonzalez Rogers
- Vince Chhabria
- 3:20-cv-00070
- U.S. District Court · Northern District of California
- 1
In Bonilla v. Gonzalez Rogers, Judge Chhabria dismissed with prejudice Bonilla’s mandamus action against federal judges because they were immune and habeas was the proper vehicle.
Steven Wayne Bonilla’s mandamus action was dismissed with prejudice, and the four federal district judges he sued were protected from the requested relief by judicial immunity.
What happened
In Bonilla v. Gonzalez Rogers, Steven Wayne Bonilla, a state inmate representing himself, sought a court order requiring four federal judges to enter a default judgment based on rulings in his cases.
The court explained that federal judges are protected from lawsuits over actions taken in their judicial roles, including requests for orders or other non-money remedies. It also said Bonilla’s claims concerned his state criminal case and belonged in his pending federal case challenging that matter.
The court dismissed the action with prejudice because changing the petition would not fix the problems. Judge Vince Chhabria also directed the clerk to file no further documents in the case after it closed.
The detailed version
- Bonilla v. Gonzalez Rogers · No. 3:20-cv-00070
- Vince Chhabria
- Jan. 15, 2020
Background
Steven Wayne Bonilla, identified as a state inmate, filed a self-represented petition seeking a writ of mandamus—a court order directing action. He sought a default judgment against four federal district judges based on rulings those judges made in his cases.
Court’s reasoning
The court held that federal judges have absolute immunity from civil liability for acts performed in their judicial capacity. The protection extends beyond damages to declaratory, injunctive, and other equitable relief. The opinion contrasted this protection with the judicial immunity available to state judges sued under 42 U.S.C. § 1983.
The court also stated that Bonilla’s underlying claims concern his state criminal case. According to the opinion, those claims are properly brought in his pending federal proceeding challenging that criminal matter.
Disposition
The court dismissed this action with prejudice because amendment would be futile. It directed the clerk to file no further documents in the case after it was closed.
Read the full 1-page opinion on CourtListener, the free public archive maintained by the Free Law Project.