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N.D. Cal.Procedural orderFiled Jan. 15, 2020

Bonilla v. Chhabria

Judge
Vince Chhabria
Docket
3:20-cv-00071
Court
U.S. District Court · Northern District of California
Pages
2
Civil ProcedureHabeasPro Se
In one sentence

In Bonilla v. Chhabria, Judge Chhabria dismissed with prejudice Bonilla’s self-represented request for a court order against three federal judges because they were immune.

Who this affects

Steven Wayne Bonilla’s action was dismissed with prejudice, ending his request for a default judgment against the three federal district judges.

What happened

Bonilla v. Chhabria involved Steven Wayne Bonilla, a state inmate representing himself, who sought a court order requiring three federal district judges to face a default judgment over rulings in their cases.

The court said federal judges are fully protected from civil claims for actions taken in their judicial roles, including requests for orders or other non-money relief. It also said Bonilla’s claims about his state criminal case belonged in his pending proceedings challenging that case.

Judge Vince Chhabria ruled that this was not a situation requiring him to step aside and dismissed the action with prejudice because changing the petition would not fix the problems. The clerk was instructed not to file more documents after the case closed.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Chhabria · No. 3:20-cv-00071
Judge
Vince Chhabria
Date
Jan. 15, 2020

Background

Steven Wayne Bonilla, a state inmate proceeding without a lawyer, filed a petition for a writ of mandamus. A writ of mandamus is a court order directing an official or court to take a required action. Bonilla sought a default judgment against three federal district judges based on rulings they made in cases before them.

Court’s reasoning

The court held that a federal judge has absolute judicial immunity from civil liability for acts performed in the judge’s judicial capacity. The court explained that this protection extends beyond claims for money damages to requests for declaratory, injunctive, and other equitable relief.

The court also stated that Bonilla’s underlying claims concerned his state criminal case and therefore were properly brought in his pending proceedings challenging that case. The court further determined that its judge’s impartiality could not reasonably be questioned.

Disposition

The court dismissed the action with prejudice because amendment would be futile. The order also directed the Clerk to file no further documents in the case after it was closed. The order was signed by Vince Chhabria, United States District Judge.

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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