Bonilla v. Blum
- Phyllis Hamilton
- 4:21-cv-02643
- U.S. District Court · Northern District of California
- 2
Bonilla v. Chhabria: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without fees and faced additional legal bars.
Steven Wayne Bonilla’s listed civil-rights cases were dismissed with prejudice and closed; future documents submitted in those cases were to be returned without filing.
What happened
Bonilla v. Judge Vince Chhabria and others involved multiple civil-rights lawsuits filed by Steven Wayne Bonilla, a condemned state prisoner. He challenged his conviction and the handling of his petitions and other cases by state and federal courts.
The court found that Bonilla could not proceed without paying filing fees because he had previously been barred from that status and had not shown an immediate danger of serious physical injury. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, meaning the same cases could not be brought again. She also directed the clerk to end all pending motions, close the cases, and return future documents submitted in them without filing them.
The detailed version
- Bonilla v. Blum · No. 4:21-cv-02643
- Phyllis Hamilton
- Apr. 21, 2021
Background
Steven Wayne Bonilla, identified as a state prisoner facing a death sentence, 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 concerning Bonilla’s underlying conviction and the handling of his petitions and other cases in state and federal court.
The opinion also notes that Bonilla had a pending federal petition challenging his conviction in the same district, with appointed counsel, and was represented by counsel in state court proceedings concerning his conviction.
Fee status
Bonilla was disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), which limits that status for a prisoner who has accumulated qualifying prior dismissals. An exception applies when the prisoner shows that he faced an immediate danger of serious physical injury when the complaint was filed. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other legal grounds
The court further stated that, even if an application to proceed without paying the fee were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not resolve the underlying validity of Bonilla’s conviction or the other claims on their merits.
Ruling and case status
The court dismissed the cases with prejudice. The order also determined that the repetitive and allegedly frivolous filings did not provide a basis for questioning the assigned 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 those closed cases.
Disposition
The listed cases were dismissed with prejudice. The order is classified as a procedural order because the dismissals rested on filing-fee restrictions and other threshold legal bars rather than a decision on the underlying claims.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.