Bonilla v. Napa County
- Vince Chhabria
- 3:20-cv-00719
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Napa County, Judge Chhabria dismissed the case with prejudice because Bonilla showed no imminent danger and Heck barred the lawsuit.
Steven Wayne Bonilla's § 1983 lawsuit against Napa County was dismissed with prejudice, and he could not proceed without paying the filing fee because the court found no imminent danger.
What happened
In Bonilla v. Napa County, Steven Wayne Bonilla, a state inmate, sued Napa County under a federal civil-rights law. He represented himself and sought permission to file without paying the filing fee.
The court said Bonilla had previously been disqualified from filing without paying under a rule limiting repeated fee-waiver filings, unless he faced imminent danger of serious physical injury when he filed. The court found that his allegations did not show such danger.
Judge Chhabria also said that, even if Bonilla had been allowed to file without paying, the lawsuit would be barred under a Supreme Court rule called Heck v. Humphrey. The court dismissed the case with prejudice, directed the Clerk to close it, and ordered that later documents Bonilla submitted be returned without filing.
The detailed version
- Bonilla v. Napa County · No. 3:20-cv-00719
- 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 Napa County. He proceeded without a lawyer and asked to file without paying the filing fee.
The court stated that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the fee unless he was under imminent danger of serious physical injury when he filed the complaint. The court cited two prior related proceedings involving that disqualification. It concluded that the allegations in this complaint did not show imminent danger at the time of filing.
Ruling
The court ruled that Bonilla could not proceed without paying the filing fee. It further stated that, even if his request to proceed without paying had been granted, the lawsuit would be barred under Heck v. Humphrey, which the order cited as a separate legal bar. The court therefore dismissed the case with prejudice.
The order also rejected any basis for questioning the undersigned judge's impartiality. The Clerk was directed to close the case and to return, without filing, any further documents Bonilla submitted after the case was closed. The order was signed by United States District Judge Vince Chhabria on March 12, 2020.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.