Bonilla v. Napa County
- Phyllis Hamilton
- 4:21-cv-02816
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Vince Chhabria, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because filing-fee restrictions and other legal bars applied.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected the named federal judges, state judges, and counties as defendants, and directed the clerk to return future documents submitted in the closed cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria and others, the court addressed multiple related civil-rights complaints filed by Bonilla, a state prisoner proceeding without a lawyer. The complaints named federal judges, state judges, and counties and sought relief connected to his conviction and the handling of his other court cases.
The court said Bonilla could not proceed without paying filing fees because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if fee-free filing had been allowed, legal doctrines identified in the order would bar the lawsuits. It dismissed the cases with prejudice, ended the pending motions, closed the cases, and directed the clerk to return future documents without filing them.
Judge Phyllis J. Hamilton also stated that the repetitive and allegedly frivolous filings did not provide a reason to question her impartiality. The order was dated April 21, 2021.
The detailed version
- Bonilla v. Napa County · No. 4:21-cv-02816
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla filed multiple civil-rights complaints under 42 U.S.C. § 1983. He was a state prisoner and a condemned prisoner, and he filed the complaints without a lawyer. The defendants included various federal judges, state judges, and counties. The order states that the complaints presented very similar claims and sought relief concerning Bonilla’s underlying conviction or the handling of his other petitions and cases in state and federal court.
The order covered the following case numbers: 21-cv-02182-PJH, 21-cv-02643-PJH, 21-cv-02644-PJH, 21-cv-02646-PJH, 21-cv-02740-PJH, 21-cv-02761-PJH, 21-cv-02763-PJH, 21-cv-02764-PJH, 21-cv-02765-PJH, 21-cv-02799-PJH, 21-cv-02801-PJH, 21-cv-02808-PJH, 21-cv-02809-PJH, 21-cv-02810-PJH, 21-cv-02811-PJH, 21-cv-02812-PJH, 21-cv-02813-PJH, 21-cv-02814-PJH, 21-cv-02815-PJH, and 21-cv-02816-PJH.
Filing-fee restriction
The court explained that Bonilla had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g). That statute generally prevents a prisoner who has accumulated qualifying prior dismissals from proceeding without paying the filing fee unless the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court concluded that the allegations did not show such an imminent danger. As a result, Bonilla could not proceed without paying the filing fees.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying filing fees had been granted, the lawsuits would be barred under the legal doctrines identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim explanation of how each doctrine applied.
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 additional documents Bonilla submitted in the closed cases.
The order additionally stated that the repetitive and frivolous nature of the filings did not create a reason to question the undersigned judge’s impartiality. Judge Phyllis J. Hamilton signed the order on April 21, 2021.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.