Bonilla v. Chhabria
- Phyllis Hamilton
- 4:20-cv-09392
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice, citing IFP disqualification and several legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice; the court also closed the cases and directed the clerk not to file further documents submitted in them.
What happened
In Bonilla v. Chhabria, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed several similar civil-rights cases under 42 U.S.C. § 1983. He sued various federal and state court judges and municipalities, seeking relief related to his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying the filing fee unless he showed an imminent danger of serious physical injury. The complaints did not show that danger. The court also said that, even if he could proceed without paying the fee, the lawsuits were barred by several legal doctrines and decisions, including rules concerning challenges to convictions and interference with ongoing proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Chhabria · No. 4:20-cv-09392
- Phyllis Hamilton
- Jan. 27, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal and state court judges and several municipalities. The complaints presented similar claims concerning Bonilla’s underlying conviction and the handling of his other self-represented habeas petitions and court cases.
The opinion also noted that Bonilla had a pending federal habeas petition in the district court with appointed counsel and was represented by counsel in state habeas proceedings.
Filing-fee status
Bonilla sought, or potentially sought, permission to proceed without paying the filing fee. The court held that 28 U.S.C. § 1915(g) disqualified him from proceeding this way unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such imminent danger.
Other legal bars
The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis explaining which cited bar applied to which complaint.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. The court separately concluded that the repetitive and frivolous nature of the filings did not provide a basis to question the undersigned judge’s impartiality.
Judge
The order was signed by Phyllis J. Hamilton, United States District Judge.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.