Bonilla v. Marin County Superior Court
- Phyllis Hamilton
- 4:23-cv-05398
- 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 paying fees and his claims were barred.
Steven Wayne Bonilla and the multiple civil-rights cases identified in the opinion; the court also directed the clerk to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Bonilla v. Chhabria, Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against federal judges and federal and state courts. He sought relief related to his conviction and the way other courts handled his cases.
The court said Bonilla could not proceed without paying the filing fees because he had previously been barred from proceeding without fees, and his complaints did not show an immediate danger of serious physical injury when he filed them. The court also said that, even if he could proceed without fees, the lawsuits were barred by several legal rules and dismissed the cases with prejudice.
Judge Phyllis J. Hamilton rejected the stated concern about her impartiality, directed the clerk to terminate all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing.
The detailed version
- Bonilla v. Marin County Superior Court · No. 4:23-cv-05398
- 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 opinion lists these case numbers: 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, 23-cv-5520-PJH, and related cases identified in the caption.
The court said the complaints presented nearly identical claims and named various federal judges and federal and state courts as defendants. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The opinion also states that he had a pending federal petition challenging his conviction or detention with appointed counsel.
Filing-fee restriction
To the extent Bonilla sought permission to proceed without paying the filing fee, the court applied 28 U.S.C. § 1915(g). That provision generally disqualifies a prisoner from proceeding without the fee after qualifying prior dismissals, unless the prisoner was in imminent danger of serious physical injury when the complaint was filed. The court stated that Bonilla had already been disqualified under that provision and that his allegations did not show imminent danger at the relevant time.
Other barriers identified by the court
The court further stated that, even if an application to proceed without paying 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 does not separately explain which cited rule applied to which case or claim.
Ruling and case administration
The court dismissed the cases with prejudice. It also concluded that these cases did not present a basis to question the undersigned judge's impartiality because of the repetitive and frivolous nature of the filings. A footnote states that Bonilla named the undersigned judge as a defendant in one case, but the provided opinion text cuts off before completing the explanation.
The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
Disposition
The court dismissed all identified cases with prejudice and ordered the cases closed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.