Bonilla v. San Mateo County
- Phyllis Hamilton
- 4:21-cv-02811
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without filing fees and the suits were legally barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, the pending motions were terminated, and the cases were closed. The order also directed the clerk to return later documents submitted in those closed cases without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria, et al., Bonilla, a state prisoner, filed multiple civil-rights lawsuits without a lawyer. He named federal judges, state judges, and counties as defendants and challenged his conviction and the handling of his other court cases.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate risk of serious physical injury. The allegations did not show that risk when he filed the complaints. The court also said the lawsuits would be barred for additional legal reasons even if he had been allowed to proceed without paying fees.
The court dismissed the cases with prejudice, ended all pending motions, and ordered the clerk to close the cases and return future documents without filing them. Judge Phyllis J. Hamilton also declined to recuse herself, explaining that the repetitive and frivolous filings did not reasonably call her impartiality into question.
The detailed version
- Bonilla v. San Mateo County · No. 4:21-cv-02811
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, a state prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The opinion lists multiple case numbers, including 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. The complaints named various federal judges, state judges, and counties as defendants. They presented similar claims concerning Bonilla’s underlying conviction and the handling of his other prisoner petitions and court cases.
The opinion states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel, and was represented by counsel in state-court proceedings. It also states that he had previously been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaint.
Court’s Analysis
The court concluded that the allegations did not show that Bonilla faced an immediate danger of serious physical injury at the time of filing. He therefore could not proceed without paying the required filing fees. The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in the opinion, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and certain challenges to other courts’ actions.
The court separately considered whether Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. It concluded that these were not cases requiring her recusal. The opinion cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases. It also ordered the clerk to return, without filing, any further documents Bonilla submitted in the closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.