Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:23-cv-05516
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed the self-represented prisoner’s multiple civil-rights cases with prejudice because he could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple self-represented civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return later submissions without filing.
What happened
In Bonilla v. Judge Vince Chhabria et al., Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical self-represented civil-rights complaints against various federal judges and federal and state courts. He sought relief concerning his underlying conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying filing fees 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 were allowed to proceed without paying fees, several legal rules and precedents barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to terminate all pending motions and close the cases, and ordered that additional documents Bonilla submitted in the closed cases be returned without filing. Judge Hamilton also concluded that recusal was not required based on the repetitive and frivolous filings.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:23-cv-05516
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple self-represented civil-rights complaints under 42 U.S.C. § 1983. The cases were assigned multiple case numbers, including 23-cv-4540-PJH, 23-cv-5164-PJH, 23-cv-5165-PJH, 23-cv-5278-PJH, 23-cv-5299-PJH, 23-cv-5300-PJH, 23-cv-5350-PJH, 23-cv-5389-PJH, 23-cv-5390-PJH, 23-cv-5391-PJH, 23-cv-5393-PJH, 23-cv-5394-PJH, 23-cv-5397-PJH, 23-cv-5398-PJH, 23-cv-5399-PJH, 23-cv-5400-PJH, 23-cv-5458-PJH, 23-cv-5459-PJH, 23-cv-5460-PJH, 23-cv-5465-PJH, 23-cv-5516-PJH, 23-cv-5517-PJH, 23-cv-5519-PJH, and 23-cv-5520-PJH.
The complaints presented nearly identical claims against various federal judges and federal and state courts. The court said Bonilla sought relief concerning his underlying conviction or the handling of his other cases in state and federal court. The opinion also noted that Bonilla had a pending federal petition challenging his detention or conviction in the same court, with appointed counsel.
Proceeding Without Paying Filing Fees
The court addressed Bonilla’s possible requests to proceed in forma pauperis, meaning without prepaying 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 under imminent danger of serious physical injury when the complaint was filed.
The court stated that Bonilla had previously been disqualified from proceeding without paying filing fees. It found that the allegations in these complaints did not show imminent danger of serious physical injury at the time of filing. The court therefore concluded that Bonilla could not proceed without paying the filing fees.
Additional Bars to the Lawsuits
The court further ruled that, even if an application to proceed without paying filing fees were granted, the lawsuits would be barred under the authorities it cited: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide separate claim-by-claim analysis for each complaint.
Recusal
Bonilla named Judge Hamilton as a defendant in one of the cases. The court stated that the cases did not present circumstances in which Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to hear assigned cases.
Disposition
Judge Hamilton ordered that the cases be dismissed 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 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.