Bonilla v. Mendocino County
- Vince Chhabria
- 3:20-cv-00560
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Mendocino County, Judge Chhabria dismissed Bonilla’s civil-rights case with prejudice after finding no imminent danger and stating Heck barred it.
Steven Wayne Bonilla’s civil-rights case against Mendocino County was dismissed with prejudice, and he could not proceed without paying the filing fee because the court found no imminent danger.
What happened
Bonilla v. Mendocino County involved Steven Wayne Bonilla, a state inmate proceeding without a lawyer, who filed a civil-rights action under federal law against Mendocino County.
The court said Bonilla was disqualified from proceeding without paying the filing fee unless he showed that he faced an imminent danger of serious physical injury when he filed. The court found that his allegations did not make that showing. It also said that, even if he could proceed without paying, another legal rule, Heck v. Humphrey, barred the lawsuit.
Judge Vince Chhabria dismissed the case with prejudice and directed the clerk to close it and return any further documents Bonilla submitted. Judge Chhabria also stated that there was no reasonable basis to question his impartiality.
The detailed version
- Bonilla v. Mendocino County · No. 3:20-cv-00560
- Vince Chhabria
- Mar. 12, 2020
Background
Steven Wayne Bonilla, identified as a state inmate, filed a civil action without a lawyer under 42 U.S.C. § 1983 against Mendocino County. The opinion does not describe the underlying factual allegations in detail.
Filing-fee eligibility
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That restriction permits such a litigant to proceed without paying only if the complaint shows that he was under imminent danger of serious physical injury when he filed it. The court found that Bonilla’s allegations did not show imminent danger at the relevant time.
Heck bar
The court additionally stated that, even if Bonilla’s application to proceed without paying the filing fee were granted, the lawsuit would be barred under Heck v. Humphrey, 512 U.S. 477 (1994). The opinion does not explain the specific basis for applying that rule beyond stating that it would bar the lawsuit.
Disposition
Judge Vince Chhabria ordered that the case be dismissed with prejudice. The clerk was directed to close the case and return, without filing, any further documents Bonilla submitted after the case was closed. The court also stated that this was not a case in which the judge’s impartiality could reasonably be questioned. The order does not identify a separate motion seeking the judge’s recusal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.