Bonilla v. Maier
- Phyllis Hamilton
- 4:25-cv-00904
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Averill, Judge Hamilton dismissed multiple prisoner civil-rights cases with prejudice because Bonilla could not proceed without paying and his claims were barred.
Steven Wayne Bonilla’s listed civil-rights cases were dismissed with prejudice and closed. The named federal and state judges and other officials were defendants in those cases.
What happened
Steven Wayne Bonilla, a condemned state prisoner representing himself, filed multiple nearly identical civil-rights lawsuits against various federal and state judges and other officials. The lawsuits sought relief related to his conviction and the handling of his other court cases.
The court said Bonilla was barred from proceeding without paying the filing fees unless he showed that he faced an immediate serious physical danger when he filed. The complaints did not make that showing. The court also said that, even if he were allowed to proceed without paying, the lawsuits would be barred by several legal doctrines concerning challenges to convictions, ongoing proceedings, and court judgments.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future documents without filing them.
The detailed version
- Bonilla v. Maier · No. 4:25-cv-00904
- Phyllis Hamilton
- Jan. 30, 2025
Background
Steven Wayne Bonilla, described as a state prisoner and a condemned prisoner, filed multiple complaints under 42 U.S.C. § 1983, the federal civil-rights statute. He represented himself in these cases. The complaints presented nearly identical claims and named various federal and state judges and other officials as defendants. The opinion says Bonilla sought relief concerning his underlying conviction or the way his other state and federal cases had been handled.
The opinion also notes that Bonilla had a pending federal petition challenging his imprisonment in the same court with appointed counsel, and that he was represented by counsel in state-court proceedings challenging his imprisonment.
Reasons for dismissal
The court addressed Bonilla’s ability to proceed without paying the filing fees. Under 28 U.S.C. § 1915(g), a prisoner disqualified from that payment-free procedure may proceed only if the complaint shows that the prisoner faced imminent danger of serious physical injury when the complaint was filed. The court found that Bonilla’s allegations did not show such danger, so he could not proceed without paying the fees.
The court further stated that, even if an application to proceed without paying fees were granted, the lawsuits would be barred under several doctrines identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each doctrine’s application to each complaint.
Ruling and effect
The court dismissed the cases with prejudice. It also said the filings did not provide a basis to question Judge Hamilton’s impartiality because of their repetitive and frivolous nature. The clerk was ordered to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
The opinion lists numerous case numbers, including 24-cv-9255-PJH, 24-cv-9265-PJH, and multiple 2025 cases. It does not identify the defendant as “Maier” in the caption or body provided; the caption identifies the defendants as “Averill et. al.”
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.