Bonilla v. Napa County Superior Court
- Phyllis Hamilton
- 4:23-cv-05389
- U.S. District Court · Northern District of California
- 3
Bonilla v. Chhabria: Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla could not proceed without prepayment and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice and closed. The defendants named in those cases, including federal judges and federal and state courts, were affected by the case closures. The clerk was directed to return future filings in the closed cases without filing them.
What happened
In Bonilla v. Judge Vince Chhabria et al., Steven Wayne Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights cases against federal judges and federal and state courts. He challenged his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without prepaying the filing fees because his complaints did not show that he faced an immediate risk of serious physical injury when he filed them. The court also said that, even if he could proceed without prepayment, the lawsuits were barred by several legal rules. It dismissed the cases with prejudice, terminated pending motions, and closed the cases.
Judge Hamilton also declined to recuse herself, explaining that the repetitive and frivolous filings did not create a reasonable question about her impartiality. The clerk was directed to return future filings in the closed cases without filing them.
The detailed version
- Bonilla v. Napa County Superior Court · No. 4:23-cv-05389
- Phyllis Hamilton
- Oct. 30, 2023
Background
Steven Wayne Bonilla, described by the court as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The order covers the case numbers listed in the caption, 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 court said the complaints presented 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 court also noted that he had a pending federal petition challenging his detention or conviction with appointed counsel.
Reason for Dismissal
The court explained that Bonilla had previously been disqualified from proceeding without prepaying filing fees under 28 U.S.C. § 1915(g). That statute permits a disqualified prisoner to proceed without prepayment only when the complaint shows that the prisoner was in immediate danger of serious physical injury when the complaint was filed. The court found that these complaints did not show such danger, so Bonilla could not proceed without prepaying the fees.
The court further stated that, even if an application to proceed without prepayment 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, and Mullis v. U.S. Bankruptcy Court. The order did not provide a separate claim-by-claim analysis of those rules.
Rulings and Case Status
The court dismissed the cases with prejudice. It directed the clerk to terminate all pending motions and close the cases. It also directed the clerk to return, without filing, any further documents Bonilla submitted in the closed cases.
Bonilla named the judge who signed the order as a defendant in one of the cases. The court nevertheless declined to recuse itself, stating that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. Judge Phyllis J. Hamilton signed the order on October 30, 2023.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.