Bonilla v. Mayfield
- Phyllis Hamilton
- 4:25-cv-00353
- U.S. District Court · Northern District of California
- 3
Bonilla v. Averill: Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The order also terminated pending motions, closed the cases, and required the clerk to return later submissions without filing them.
What happened
In Bonilla v. Averill, Steven Wayne Bonilla, a state prisoner proceeding without a lawyer, filed many nearly identical civil-rights lawsuits against federal and state judges and other officials. He challenged his conviction and how other state and federal cases had been handled.
The court said Bonilla was barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury when he filed. The complaints did not show that danger. The court also said the lawsuits would be barred even if he could proceed without paying fees, under several rules and doctrines protecting criminal judgments and ongoing court proceedings.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, directed the clerk to end all pending motions and close the cases, and ordered that further documents Bonilla submitted in the closed cases be returned without filing. The court also declined to question its own impartiality based solely on Bonilla's repetitive filings.
The detailed version
- Bonilla v. Mayfield · No. 4:25-cv-00353
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, the federal statute that allows certain civil-rights claims against state actors. The court addressed numerous related cases, including case numbers 24-cv-9255-PJH, 24-cv-9265-PJH, and the listed 2025 case numbers.
The complaints presented nearly identical claims and named various federal and state judges and other officials as defendants. Bonilla sought relief concerning his underlying conviction and the handling of his other state and federal cases. The opinion also states that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state proceedings challenging his conviction.
Court's analysis
The court stated that Bonilla had been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he was in immediate danger of serious physical injury when he filed the complaints. The court found that the allegations did not show such danger.
The court further stated that, even if an application to proceed without paying the filing fee 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 did not provide a separate claim-by-claim explanation of which cited doctrine applied to which complaint.
The court also rejected any suggestion that the judge's impartiality could reasonably be questioned merely because Bonilla had filed repetitive and allegedly frivolous cases, noting that judges generally have a duty to decide cases assigned to them absent legitimate grounds for recusal.
Disposition
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.
This is a procedural order because the court disposed of the cases based on filing-fee eligibility and threshold legal bars rather than deciding the underlying civil-rights claims on their merits.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.