Bonilla v. Sonoma County Superior Court
- Phyllis Hamilton
- 4:23-cv-05400
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Vince Chhabria et al., Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla, whose multiple civil-rights cases were dismissed with prejudice, and the judges and courts he named as defendants.
What happened
In Steven Wayne Bonilla v. Judge Vince Chhabria et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases. He sued various federal judges and federal and state courts over his conviction and how his other cases had been handled.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. The allegations did not show that danger when he filed the complaints. The court also said the lawsuits would be barred even if he were allowed to proceed without paying fees.
The court dismissed the cases with prejudice, ended all pending motions, and closed the cases. Judge Phyllis J. Hamilton also ordered the clerk to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Sonoma County Superior Court · No. 4:23-cv-05400
- 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 order covers multiple related cases. Bonilla is described as a condemned prisoner and has a pending federal petition challenging his custody in the same court, where he has appointed counsel.
The complaints presented nearly identical claims against various federal judges and federal and state courts. The complaints sought relief concerning Bonilla’s underlying conviction or the way state and federal courts had handled his other cases.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified from proceeding without paying filing fees under 28 U.S.C. § 1915(g), unless he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger at the time of filing. Bonilla therefore could not proceed without paying the filing fee.
Other Bars to the Lawsuits
The court further stated that, even if Bonilla’s application to proceed without paying fees 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 order did not provide a separate claim-by-claim analysis of which cited rule applied to which case.
Disposition
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases. The court also rejected any basis for questioning the undersigned judge’s impartiality based on the repetitive and allegedly frivolous filings. Judge Phyllis J. Hamilton signed the order. The supplied case label refers to Sonoma County Superior Court, but the opinion’s caption identifies the defendants as Judge Vince Chhabria et al. and lists multiple related case numbers.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.