Bonilla v. Clay
- Phyllis Hamilton
- 4:25-cv-00452
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and identifying procedural bars.
Steven Wayne Bonilla, whose multiple cases were dismissed with prejudice and closed; the order also directed the clerk to terminate pending motions and return later submissions without filing them.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under a federal law known as Section 1983. The complaints made nearly identical claims against various federal and state judges and other officials, challenging his conviction or 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 allegations did not show imminent danger of serious physical injury when he filed. The court also said that, even if he had been allowed to proceed without paying, legal barriers would prevent the lawsuits from going forward.
In Bonilla v. Averill, Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in those closed cases.
The detailed version
- Bonilla v. Clay · No. 4:25-cv-00452
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law used to bring certain civil-rights claims. The order covers numerous listed case numbers, beginning with 24-cv-9255-PJH and including cases filed in 2025.
The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the way state and federal courts handled his other cases. The order also states that Bonilla had a pending federal petition challenging his conviction in which he had appointed counsel, and that he was represented by counsel in state-court proceedings challenging his conviction.
Filing-fee status and legal barriers
The court stated that Bonilla had already been disqualified from proceeding without paying the filing fee under 28 U.S.C. § 1915(g), unless he showed that he faced imminent danger of serious physical injury when he filed his complaint. The court found that the allegations did not show such danger. Bonilla therefore could not proceed without paying the filing fee.
The court further ruled that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under the legal doctrines and authorities identified in the order: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The order did not decide the underlying merits of Bonilla’s claims.
Other ruling and disposition
The court rejected any suggestion that the judge’s impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It stated that a judge generally has a duty to decide assigned cases absent legitimate grounds for recusal. The order notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her in those cases.
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any further documents Bonilla submitted in the closed cases.
Classification
This is a procedural order because the court dismissed the cases based on filing-fee eligibility and threshold legal barriers without deciding whether Bonilla’s underlying civil-rights claims were legally valid.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.