Bonilla v. Santa Clara County Superior Court
- Phyllis Hamilton
- 4:23-cv-05460
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his lawsuits were barred.
Steven Wayne Bonilla's multiple federal civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and directed the clerk to return further submissions in those cases without filing them.
What happened
In Bonilla v. Chhabria, Steven Wayne Bonilla, a state prisoner representing himself, filed nearly identical civil-rights cases under a federal law against federal judges and federal and state courts. He sought relief related to his conviction and to how other courts handled his cases.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed an immediate danger of serious physical injury, which his complaints did not show. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal doctrines and statutes.
Judge Phyllis J. Hamilton dismissed all the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return any further documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Santa Clara County Superior Court · No. 4:23-cv-05460
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The opinion addresses numerous related cases, including Case Nos. 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 asserted nearly identical claims against various federal judges and federal and state courts. Bonilla sought relief concerning his underlying conviction or the way his other cases had been handled. The opinion also notes that he had a pending federal petition challenging his custody in the same court, with appointed counsel.
Filing-fee restriction
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without paying only when the complaint shows that the prisoner faced an imminent danger of serious physical injury when the complaint was filed.
The court found that Bonilla's allegations did not show such a danger. It therefore ruled that he could not proceed without paying the filing fee.
Other barriers to the lawsuits
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 or rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion did not provide a separate claim-by-claim analysis of those barriers.
Ruling and case closure
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The order also directed the clerk to terminate all pending motions and close the cases. It instructed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
The court additionally rejected the suggestion that the judge's impartiality could reasonably be questioned because of Bonilla's repetitive and allegedly frivolous filings. The opinion states that Bonilla named the judge as a defendant in one case but did not provide a legitimate basis for questioning the judge's impartiality.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.