In Re the Matter of Steven Wayne Bonilla
- Phyllis Hamilton
- 4:25-cv-01231
- U.S. District Court · Northern District of California
- 3
In Steven Wayne Bonilla v. Linda Clark, Judge Hamilton dismissed multiple civil-rights cases with prejudice because Bonilla did not qualify for fee-free filing and his claims were barred.
Steven Wayne Bonilla and the defendants in the sixteen listed cases are directly affected. The cases were dismissed with prejudice, pending motions were terminated, the cases were closed, and further documents submitted in them must be returned without filing.
What happened
Steven Wayne Bonilla v. Linda Clark involved multiple nearly identical civil-rights lawsuits filed by Bonilla, a state prisoner proceeding without a lawyer. The opinion says he is a condemned prisoner with a pending federal petition challenging his confinement and separate state proceedings in which he has lawyers.
The court found that Bonilla did not show he faced an immediate risk of serious physical harm when he filed, so he could not proceed without paying filing fees. The court also said that, even if he had qualified for that status, legal rules barred the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, closed the cases, and directed the clerk to return any further documents Bonilla submits in them without filing them.
The detailed version
- In Re the Matter of Steven Wayne Bonilla · No. 4:25-cv-01231
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla filed multiple nearly identical complaints under 42 U.S.C. § 1983, a statute that permits certain civil-rights claims against government actors. The opinion identifies Bonilla as a state prisoner and a condemned prisoner. It also states that he had a pending federal petition challenging his confinement in this court, with appointed counsel, and state-court proceedings in which he was represented by counsel.
The opinion’s text is incomplete in the passage describing whom Bonilla named and the subjects of his claims. It states that he challenged matters involving his underlying conviction and the handling of his other cases by state and federal courts.
Filing-fee status and legal bars
Bonilla sought, or potentially sought, permission to proceed without paying filing fees. Under 28 U.S.C. § 1915(g), a prisoner who has accumulated the relevant qualifying dismissals generally cannot proceed without prepaying the filing fee unless he was in immediate danger of serious physical injury when he filed. The court found that the complaints did not show such danger at the time of filing.
The court further held that, even if Bonilla’s requests to proceed without paying fees were granted, the lawsuits would be barred under the legal rules identified in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, and Mullis v. U.S. Bankruptcy Court. The court described Bonilla as having an extensive history of filing similar frivolous cases.
Disposition
The court dismissed the listed 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 submits in those closed cases.
The court separately rejected the apparent basis for questioning the assigned judge’s impartiality. The opinion states that the repetitive and frivolous nature of the filings did not create a reasonable basis to question the judge’s impartiality. The order was signed by Judge Phyllis J. Hamilton.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.