Bonilla v. Mendocino County
- Phyllis Hamilton
- 4:21-cv-02813
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and citing additional legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk not to file further documents submitted in those closed cases.
What happened
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases under a federal law allowing claims against officials who violate constitutional rights. He sued federal judges, state judges, and counties, seeking relief related to his conviction and the handling of his other cases.
The court found that Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed the complaints. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules concerning challenges to convictions, ongoing state proceedings, and interference with other courts.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases. The court also said recusal was not warranted and directed the clerk to return future documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Mendocino County · No. 4:21-cv-02813
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal statute that permits certain civil-rights claims against state or local officials. The order lists multiple related case numbers. The defendants included various federal judges, state judges, and counties. The complaints presented very similar allegations and sought relief concerning Bonilla’s underlying conviction and the handling of his self-filed petitions for federal relief and other cases.
The order also states that Bonilla had a pending federal petition for relief from his conviction in the same court with appointed counsel, and that he was represented by counsel in state proceedings concerning his conviction.
Proceeding Without Paying Filing Fees
The court stated that Bonilla had previously been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he showed that he was in imminent danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such imminent danger. Therefore, Bonilla could not proceed without paying the filing fees.
Other Legal Bars
The court further stated that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under Heck v. Humphrey, which limits certain civil-rights claims that would undermine a conviction; Younger v. Harris, which concerns federal interference with ongoing state proceedings; and two cited decisions concerning challenges to other courts and proceedings. The opinion does not provide a separate claim-by-claim analysis of those bars.
Ruling and Case Closure
The court dismissed the cases with prejudice. It also stated that the repetitive and frivolous nature of the filings did not provide a reason to question the undersigned judge’s impartiality. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases. 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.