Bonilla v. Chhabria
- Phyllis Hamilton
- 4:22-cv-03445
- U.S. District Court · Northern District of California
- 3
Bonilla v. Marin County Superior Court: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla's multiple § 1983 lawsuits were dismissed with prejudice. The order also affected the named judges, courts, and government officials because the cases against them were closed.
What happened
In Bonilla v. Marin County Superior Court, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against judges, courts, and government officials. He sought relief concerning his conviction and the handling of his other cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate risk of serious physical injury when he filed. The complaints did not make that showing. The court also said the lawsuits would be barred under several legal doctrines even if fee waivers were available.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Chhabria · No. 4:22-cv-03445
- Phyllis Hamilton
- June 17, 2022
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while representing himself. The cases presented nearly identical claims. Bonilla named dozens of federal and state judges, state courts, and federal officials as defendants. The complaints sought relief concerning his underlying conviction or the way state and federal courts had handled his other cases.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court, with appointed counsel.
Filing-fee ruling
The court explained that Bonilla had previously been disqualified from proceeding without paying the filing fee under the Prison Litigation Reform Act's “three strikes” provision, 28 U.S.C. § 1915(g). That provision permits such a prisoner to proceed without paying only if he shows that he faced an imminent danger of serious physical injury when he filed the complaint.
The court found that the allegations did not show imminent danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other grounds for dismissal
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the doctrines and rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not separately analyze each doctrine's application to each complaint.
The court also addressed its own impartiality. It found that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the undersigned judge's impartiality. A footnote states that Bonilla named the judge as a defendant in one case but offered no legitimate basis for recusal.
Disposition
The court dismissed the cases with prejudice. It ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return without filing any further documents Bonilla submitted in the closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.