Bonilla v. Alameda County Superior Court
- Phyllis Hamilton
- 4:25-cv-01721
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Alameda County Superior Court, Judge Hamilton dismissed the related civil-rights cases with prejudice because Bonilla could not proceed without fees and his claims were barred.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, all pending motions were terminated, and the cases were closed. Future documents submitted in those closed cases were to be returned without filing.
What happened
In Bonilla v. Alameda County Superior Court, Steven Wayne Bonilla filed multiple nearly identical civil-rights complaints without a lawyer. The opinion describes him as a state prisoner with a pending federal petition challenging his imprisonment and separate state proceedings, both involving lawyers.
The court said Bonilla had previously been barred from proceeding without paying filing fees unless he showed that he faced an immediate danger of serious physical injury. The allegations did not show such danger when he filed the complaints. The court also said that, even if he could proceed without those fees, several legal rules would bar the lawsuits.
The court dismissed the cases with prejudice, terminated all pending motions, and ordered the clerk to close the cases and return future filings without filing them. Judge Phyllis J. Hamilton also rejected the suggestion that she should step aside because of Bonilla’s repeated filings.
The detailed version
- Bonilla v. Alameda County Superior Court · No. 4:25-cv-01721
- Phyllis Hamilton
- Feb. 28, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple complaints under 42 U.S.C. § 1983, a federal law that allows claims for certain violations of constitutional rights by state actors. He filed the complaints without a lawyer and presented nearly identical claims. The opinion also states that Bonilla is a condemned prisoner with a pending federal petition in this court, where he has appointed counsel, and state proceedings in which he is represented by counsel.
Proceeding Without Filing Fees
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that 28 U.S.C. § 1915(g) barred him from doing so unless he was in immediate danger of serious physical injury when he filed each complaint. The court relied on Bonilla’s prior filing history and found that the allegations did not show such danger at the relevant time.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without filing fees were granted, the lawsuits would be barred under several legal rules and decisions, including rules concerning challenges to criminal convictions, interference with ongoing state proceedings, and certain claims against federal courts or judges. The opinion did not resolve the underlying claims on their merits.
Ruling
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 the closed cases. The court also concluded that its judge’s impartiality could not reasonably be questioned merely because of the repetitive and frivolous nature of the filings. Judge Phyllis J. Hamilton signed the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.