Bonilla v. San Bernardino County Superior Court
- Phyllis Hamilton
- 4:23-cv-05459
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Vince Chhabria et al., Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without paying fees and the suits were legally barred.
Steven Wayne Bonilla and his multiple related civil-rights cases. The dismissal with prejudice ended those cases, terminated their pending motions, and directed the clerk not to file further documents submitted in 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 various federal judges and federal and state courts. He sought relief concerning his conviction and the handling of his other cases.
The court ruled that Bonilla could not proceed without paying the filing fees because he had previously been disqualified from that status and his complaints did not show an immediate serious physical danger when he filed them. The court also stated that, even if he had been allowed to proceed without paying fees, the lawsuits would be barred by several legal doctrines and precedents. It dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return later documents without filing them.
Judge Phyllis J. Hamilton also stated that the repetitive and frivolous filings did not provide a reasonable basis to question her impartiality. The order was dated October 30, 2023.
The detailed version
- Bonilla v. San Bernardino County Superior Court · No. 4:23-cv-05459
- 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 lists these related 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, and 23-cv-5520-PJH.
The complaints were nearly identical. Bonilla named various federal judges and federal and state courts as defendants and sought relief concerning his underlying conviction or the handling of his other cases. The court also noted that he was a condemned prisoner and had a pending federal petition concerning his custody, with appointed counsel.
Court’s analysis
The court addressed Bonilla’s possible request to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified from that status may proceed without paying fees only if the complaint shows that the prisoner faced an immediate danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger. It therefore held that he could not proceed without paying the filing fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under the legal rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain which bar applied to which complaint.
The court also addressed impartiality. It stated that the repetitive and frivolous nature of the filings did not create a situation in which the undersigned judge’s impartiality could reasonably be questioned. The opinion notes that Bonilla named the undersigned judge as a defendant in one case, but the provided text does not include the remainder of the footnote explaining that point.
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. 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.