Bonilla v. Chhabria
- Phyllis Hamilton
- 4:23-cv-04540
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding Bonilla could not proceed without paying filing fees and that additional legal bars applied.
Steven Wayne Bonilla, the defendants named in his multiple cases, and the court clerk handling those cases. The order dismissed the listed cases with prejudice and directed the clerk to close them and return later submissions without filing them.
What happened
Bonilla v. Chhabria involved multiple nearly identical lawsuits by Steven Wayne Bonilla, a state prisoner proceeding without a lawyer. He sued various federal judges and federal and state courts under a civil-rights law, seeking relief related to his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees because his allegations did not show that he faced an immediate danger of serious physical injury when he filed. The court also stated that, even if he could proceed without those fees, the lawsuits were barred by other legal rules. It dismissed the cases with prejudice, meaning the order barred refiling these cases.
Judge Phyllis J. Hamilton also said the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality. The clerk was directed to terminate pending motions, close the cases, and return future documents Bonilla submitted in them without filing them.
The detailed version
- Bonilla v. Chhabria · No. 4:23-cv-04540
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal judges and federal and state courts as defendants and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled. The opinion also states that Bonilla is a condemned prisoner and has a pending federal petition concerning his imprisonment in the same court, with appointed counsel.
Filing-fee ruling
To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that he was disqualified under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed his complaints. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
Other legal bars and disposition
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 legal authorities it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The court dismissed the cases with prejudice. The opinion does not describe a decision on the validity of Bonilla’s underlying conviction or other claims; the dismissal rested on the filing-fee restriction and the stated legal bars.
Impartiality and case closure
The court stated that the cases were not ones in which the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous filings. The clerk was directed to terminate all pending motions and close the cases. The clerk was also directed to return, without filing, any further documents Bonilla submitted in those closed cases. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.