Bonilla v. Jackson
- Phyllis Hamilton
- 4:25-cv-00790
- U.S. District Court · Northern District of California
- 3
Bonilla v. Averill: Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and other legal barriers.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice. The clerk was directed to close those cases, terminate pending motions, and return later submissions without filing them.
What happened
In Steven Wayne Bonilla v. Averill et al., a state prisoner filed many nearly identical civil-rights lawsuits without a lawyer. He sued various federal and state judges and other officials, challenging his conviction and the handling of his other cases.
The court found that the complaints did not show imminent danger of serious physical injury, so Bonilla could not proceed without paying the filing fees. The court also said the lawsuits would be barred by other legal rules even if that permission were granted.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Jackson · No. 4:25-cv-00790
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints under 42 U.S.C. § 1983 without a lawyer. The complaints were nearly identical. They named various federal and state judges and other officials and sought relief concerning Bonilla’s underlying conviction or the way his other state and federal cases had been handled.
The opinion states that Bonilla is a condemned prisoner with a pending federal petition challenging his custody in the same court, where he has appointed counsel. It also states that he is represented by counsel in state-court proceedings involving his custody.
Filing-fee status and dismissal
The court explained 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 imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not make that showing.
The court further stated that, even if Bonilla’s applications to proceed without paying the filing fee were granted, the lawsuits would be barred under rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not analyze each complaint separately.
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.
The court also stated that the repetitive and allegedly frivolous nature of the filings did not provide a reasonable basis to question the assigned judge’s impartiality. The opinion notes that Bonilla named Judge Hamilton as a defendant in four of the cases but made no specific allegations against her.
Classification basis
This is a procedural order because the court dismissed the cases on filing-fee and other threshold grounds rather than deciding the underlying challenges to Bonilla’s conviction or to the handling of his other cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.