Bonilla v. Villarreal
- Phyllis Hamilton
- 4:25-cv-01979
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed multiple civil-rights cases with prejudice after finding no imminent danger and several legal barriers.
Steven Wayne Bonilla, the defendants named in the multiple cases, and the court clerk, who was directed to terminate pending motions, close the cases, and return later submissions without filing them.
What happened
In Bonilla v. Villarreal, Steven Wayne Bonilla filed multiple nearly identical civil-rights cases against judges and other officials. He challenged his conviction and the handling of his other court cases.
Bonilla is a state prisoner and was representing himself in these cases. The court found that he could not proceed without paying the filing fees because his allegations did not show that he faced imminent danger of serious physical injury when he filed them.
Judge Phyllis J. Hamilton also concluded that the lawsuits would be barred by several legal rules even if Bonilla could proceed without paying the fees. She dismissed the cases with prejudice, directed the clerk to close them, and ordered the clerk to return future documents submitted in those cases without filing them.
The detailed version
- Bonilla v. Villarreal · No. 4:25-cv-01979
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983. The order covers the case numbers 25-cv-1979-PJH, 25-cv-1980-PJH, 25-cv-2063-PJH, 25-cv-2064-PJH, 25-cv-2065-PJH, 25-cv-2178-PJH, 25-cv-2179-PJH, 25-cv-2180-PJH, 25-cv-2182-PJH, 25-cv-2183-PJH, 25-cv-2184-PJH, 25-cv-2444-PJH, 25-cv-2445-PJH, 25-cv-2513-PJH, 25-cv-2532-PJH, 25-cv-2533-PJH, 25-cv-2535-PJH, 25-cv-2536-PJH, 25-cv-2537-PJH, 25-cv-2538-PJH, 25-cv-2539-PJH, 25-cv-2540-PJH, 25-cv-2617-PJH, 25-cv-2618-PJH, 25-cv-2621-PJH, and 25-cv-2629-PJH.
Bonilla named various federal and state judges and other officials as defendants. His nearly identical complaints sought relief concerning his underlying conviction or the way his other state and federal cases had been handled. The order also notes that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state-court proceedings.
Filing-fee restriction
The court stated 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 complaint. The court found that his allegations did not show such imminent danger. As a result, he could not proceed without paying the filing fee.
Other legal barriers
The court further stated that, even if an application to proceed without paying the filing fee were granted, the lawsuits would be barred under several authorities: Heck v. Humphrey, which can prevent certain civil-rights claims that would undermine a conviction; Younger v. Harris, which limits federal interference with certain ongoing state proceedings; and two other cited decisions, Demos v. U.S. District Court and Mullis v. U.S. Bankruptcy Court. The opinion does not separately analyze each complaint or explain which cited barrier applies to each claim.
Disposition
The court dismissed the cases with prejudice. It also concluded that the repetitive and frivolous nature of the filings did not provide a reasonable basis to question the assigned judge’s impartiality. The clerk was directed to terminate all pending motions, close the cases, and return without filing any further documents Bonilla submitted in those closed cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.