Bonilla v. Chhabria
- Phyllis Hamilton
- 4:21-cv-00846
- U.S. District Court · Northern District of California
- 2
Judge Hamilton dismissed Steven Wayne Bonilla v. Judge Teri L. Jackson with prejudice after finding no imminent danger and legal bars to the claims.
Steven Wayne Bonilla's multiple civil-rights cases against various federal and state court judges; the cases were dismissed with prejudice and closed.
What happened
In Steven Wayne Bonilla v. Judge Teri L. Jackson, et al., Bonilla, a state prisoner representing himself, filed several civil-rights lawsuits against federal and state court judges. He sought relief related to his conviction and to how courts handled his other cases and petitions.
The court found that Bonilla could not use the filing-fee waiver because he had previously been disqualified from doing so and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said the lawsuits would be barred even if the fee waiver were granted because of legal rules protecting criminal judgments, ongoing state proceedings, and certain court decisions.
The court dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future filings without filing them. Judge Phyllis J. Hamilton also stated that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality.
The detailed version
- Bonilla v. Chhabria · No. 4:21-cv-00846
- Phyllis Hamilton
- Feb. 11, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal and state court judges. The complaints presented similar claims concerning Bonilla's underlying conviction and the handling of his other petitions and cases in state and federal court.
The opinion states that Bonilla had a pending federal petition concerning his imprisonment with appointed counsel and was represented by counsel in state court proceedings. Those matters were separate from these civil-rights cases.
Filing-fee waiver
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying the filing fee, unless he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger. As a result, Bonilla could not proceed without paying the filing fee.
Other legal bars
The court further stated that, even if a fee waiver had been granted, the lawsuits would be barred under several legal doctrines and decisions. These included rules that limit civil-rights challenges to criminal convictions, require federal courts to refrain from interfering with certain ongoing state proceedings, and restrict some challenges to federal court actions. The opinion did not separately analyze each complaint or claim under those authorities.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any additional documents Bonilla submitted in the closed cases.
The court additionally stated that these were not cases in which Judge Phyllis J. Hamilton's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The opinion does not identify a separate recusal motion or state that one was separately decided.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.