Bonilla v. Chhabria
- Phyllis Hamilton
- 4:22-cv-04217
- U.S. District Court · Northern District of California
- 2
In Bonilla v. Coleman, Judge Hamilton dismissed seven civil-rights cases with prejudice because Bonilla showed no imminent danger and his suits were otherwise barred.
Steven Wayne Bonilla and the defendants named in his seven nearly identical civil-rights cases, including a federal judge, state courts, and state and federal officials.
What happened
In Bonilla v. Coleman, Steven Wayne Bonilla, a condemned state prisoner proceeding without a lawyer, filed several nearly identical civil-rights lawsuits against a federal judge, state courts, and state and federal officials. He sought relief related to his conviction and the handling of other cases.
The court said Bonilla was barred from proceeding without prepaying filing fees unless he showed that he faced an imminent danger of serious physical injury when he filed. The allegations did not make that showing. The court also said that, even if he could proceed without prepaying fees, the lawsuits were barred by several legal doctrines involving challenges to convictions, ongoing proceedings, and court decisions. The cases were dismissed with prejudice, and the clerk was ordered to close them.
Judge Phyllis J. Hamilton issued the order on July 26, 2022. The order also terminated all pending motions and directed the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Chhabria · No. 4:22-cv-04217
- Phyllis Hamilton
- July 26, 2022
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 while proceeding without a lawyer. The cases were numbered 22-cv-3671-PJH, 22-cv-3767-PJH, and 22-cv-4214-PJH through 22-cv-4218-PJH. The complaints presented nearly identical claims and named a federal judge, various state courts, and several state and federal officials as defendants.
Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases. The opinion states that he had a pending federal petition challenging his conviction or confinement in the same court, with appointed counsel, and that he was represented by counsel in state court proceedings.
Ruling
The court addressed Bonilla's ability to proceed without prepaying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from proceeding without prepaying fees may do so only if the complaint shows that the prisoner was under imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla's allegations did not show imminent danger at that time.
The court further stated that, even if an application to proceed without prepaying fees 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 doctrine applied to which allegation.
The court therefore dismissed the cases with prejudice. It ordered 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. 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.