Bonilla v. Lake County Superior Court
- Phyllis Hamilton
- 4:23-cv-05390
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Chhabria, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and applying several legal bars.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The order also directs the clerk to close those cases, terminate pending motions, 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 cases against federal judges and federal and state courts. He sought relief connected to his conviction and the handling of his other court cases.
The court found that Bonilla could not proceed without paying filing fees because he had previously been barred from that status and had not shown that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if he could proceed without paying, the lawsuits would be barred by several legal rules.
Judge Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future filings in those closed cases without filing them. She also concluded that the repetitive and frivolous filings did not require her to step aside.
The detailed version
- Bonilla v. Lake County Superior Court · No. 4:23-cv-05390
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints while representing himself. The complaints were brought under 42 U.S.C. § 1983, a federal civil-rights law. The cases named various federal judges and federal and state courts as defendants and presented nearly identical claims concerning Bonilla’s underlying conviction and the handling of his other state and federal cases. The opinion also notes that Bonilla had a pending federal petition concerning his imprisonment in the same court, with appointed counsel.
Filing-fee status
The court stated that Bonilla had previously been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g). That law allows a person with the relevant filing history to proceed without paying only when the complaint shows that the person was in immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. Therefore, he 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 rules identified in 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 analysis explaining how each rule applied to each case. The court dismissed the cases with prejudice.
The court also addressed its own impartiality. Although Bonilla named the undersigned judge as a defendant in one case, the court found that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. Judge Hamilton ordered the clerk to terminate all pending motions and close the cases. She also ordered the clerk to return, without filing, any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.