Bonilla v. Del Norte County
- Vince Chhabria
- 3:20-cv-00561
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Del Norte County, Judge Chhabria dismissed Bonilla’s civil-rights case with prejudice because he could not proceed without paying fees and the case was barred by Heck.
Steven Wayne Bonilla’s civil-rights lawsuit against Del Norte County was dismissed with prejudice; the court directed the Clerk to close the case and return later submissions without filing them.
What happened
Bonilla v. Del Norte County involved Steven Wayne Bonilla, a state inmate representing himself, who sued Del Norte County under a federal civil-rights law. He sought to proceed without paying the filing fee.
The court said Bonilla was barred from proceeding without paying because his allegations did not show that he faced an immediate danger of serious physical injury when he filed the case. The court also said that, even if it allowed him to proceed without paying, the lawsuit would be barred under Heck v. Humphrey.
Judge Chhabria dismissed the case with prejudice and ordered the Clerk to close it. The Clerk was also directed to return, without filing, any additional documents Bonilla submitted after the case closed.
The detailed version
- Bonilla v. Del Norte County · No. 3:20-cv-00561
- Vince Chhabria
- Mar. 12, 2020
Background
Steven Wayne Bonilla, identified as a state inmate, filed a civil-rights action under 42 U.S.C. § 1983 against Del Norte County. He represented himself and sought permission to proceed without paying the filing fee.
Reasons for Dismissal
The court stated that Bonilla had previously been disqualified from proceeding without paying under 28 U.S.C. § 1915(g), unless he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations in this complaint did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fee.
The court also gave an independent reason for dismissal: even if Bonilla’s request to proceed without paying had been granted, the lawsuit would have been barred under Heck v. Humphrey, 512 U.S. 477, 486–87 (1994). The opinion does not describe the underlying claims in more detail.
Disposition
The court dismissed the case with prejudice. It also stated that the judge’s impartiality could not reasonably be questioned, directed the Clerk to close the case, and ordered the Clerk to return without filing any further documents Bonilla submitted after closure.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.