Bonilla v. San Francisco County
- Phyllis Hamilton
- 4:21-cv-02810
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Chhabria, Judge Hamilton dismissed the prisoner’s multiple civil-rights lawsuits with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The defendants named in those cases were various federal judges, state judges, and counties; the clerk was directed to close the cases and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria, et. al., Steven Wayne Bonilla filed multiple civil-rights lawsuits without a lawyer against federal judges, state judges, and counties. He sought relief related to his conviction and the handling of his state and federal cases.
The court said Bonilla could not proceed without paying the filing fee because his prior cases disqualified him from that fee waiver, and his complaints did not show that he faced an immediate danger of serious physical injury when he filed them. The court also said that, even if the fee waiver were granted, the lawsuits would be barred by other legal rules.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also said the repetitive filings did not provide a reason to question her impartiality.
The detailed version
- Bonilla v. San Francisco County · No. 4:21-cv-02810
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The defendants included various federal judges, state judges, and counties. The complaints presented similar claims seeking relief concerning Bonilla’s underlying conviction and the way state and federal courts handled his other cases.
The opinion also noted that Bonilla had a pending federal petition challenging his detention or conviction with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee status and legal barriers
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) disqualified him from that status unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if permission to proceed without paying filing fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying claims on their merits.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
The court also 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.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.