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N.D. Cal.Procedural orderFiled Jan. 30, 2025

Bonilla v. Courts Clerks Office

Judge
Phyllis Hamilton
Docket
4:25-cv-00450
Court
U.S. District Court · Northern District of California
Pages
3
Civil RightsSection 1983Pro SeCivil Procedure
In one sentence

Bonilla v. Averill et al.: Judge Hamilton dismissed the prisoner’s numerous civil-rights cases with prejudice and closed them.

Who this affects

Steven Wayne Bonilla’s numerous civil-rights cases were dismissed with prejudice and closed; the order also terminated pending motions and directed the clerk to return later filings in those closed cases without filing them.

What happened

In Steven Wayne Bonilla v. Averill et al., Steven Wayne Bonilla, a state prisoner representing himself, filed many nearly identical civil-rights lawsuits against judges and other officials. He sought relief related to his conviction and the handling of his other court cases.

The court said Bonilla could not proceed without paying the filing fee because he was barred from that status and had not shown an immediate risk of serious physical injury when he filed. The court also said the lawsuits would be barred for other reasons even if that status were allowed.

Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, closed the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Bonilla v. Courts Clerks Office · No. 4:25-cv-00450
Judge
Phyllis Hamilton
Date
Jan. 30, 2025

Background

Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The order covers the many case numbers listed in the caption. The complaints were nearly identical and named various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.

The order states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in this court, where he has appointed counsel. It also states that he is represented by counsel in state court proceedings.

Filing-fee status and dismissal grounds

To the extent Bonilla sought permission to proceed without paying the filing fee, the court held that 28 U.S.C. § 1915(g) disqualified him from doing so unless he showed that he was in immediate danger of serious physical injury when he filed. The court found that the complaints did not show such danger, so Bonilla could not proceed under that exception.

The court further stated that, even if a filing-fee application were granted, the lawsuits would be barred under the legal rules identified in the order, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and limits on suing federal courts or judges. The court also noted Bonilla’s extensive history of filing similar cases.

Recusal and disposition

The court rejected the suggestion that the repetitive and allegedly frivolous filings required the judge to step aside. It stated that no legitimate reason showed that Judge Hamilton’s impartiality could reasonably be questioned. The order also noted that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.

The court dismissed the cases with prejudice. The clerk was directed to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in those closed cases.

Result

The order disposed of all listed cases by dismissal with prejudice rather than deciding the underlying challenges to Bonilla’s conviction or the handling of his other cases.

The authoritative version

Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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