Bonilla v. Santa Clara County
- Phyllis Hamilton
- 4:21-cv-02809
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Judge Vince Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also affected his ability to proceed without paying the filing fee and directed the clerk to close the cases and return further submissions without filing them.
What happened
In Bonilla v. Judge Vince Chhabria, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights cases against federal judges, state judges, and counties. He brought similar claims about his conviction and how courts handled his habeas petitions and other cases.
The court found that Bonilla could not proceed without paying the filing fee because he had previously been disqualified from that status and his complaints did not show that he faced imminent danger of serious physical injury when he filed them. The court also said that, even if he could proceed without paying, the lawsuits were barred by other legal rules.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and directed the clerk to close the cases and return any further documents without filing them.
The detailed version
- Bonilla v. Santa Clara County · No. 4:21-cv-02809
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, described in the opinion as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal civil-rights statute. He represented himself in these cases. The defendants included various federal judges, state judges, and counties. The opinion states that the cases presented very similar claims concerning Bonilla’s underlying conviction and the handling of his pro se habeas petitions and other court cases.
The opinion also states that Bonilla had a pending federal habeas petition in the same court with appointed counsel and was represented by counsel in state-court habeas proceedings.
Court’s analysis
The court addressed Bonilla’s ability to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying only if the complaint shows that the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had previously been disqualified from proceeding without paying and that his allegations did not show imminent danger at the relevant time.
The court further stated that, even if an application to proceed without paying were granted, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim explanation of which cited rule applied to which case.
The court also rejected the possibility that the undersigned judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the general duty of a judge to sit on assigned cases absent legitimate grounds for recusal.
Disposition
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any additional documents Bonilla submitted in the closed cases.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.