Bonilla v. Desautels
- Phyllis Hamilton
- 4:25-cv-02063
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed multiple cases with prejudice after finding no imminent danger and concluding several legal bars applied.
Steven Wayne Bonilla’s multiple civil-rights cases were dismissed with prejudice, all pending motions were terminated, and the cases were closed; future filings in those closed cases were to be returned without filing.
What happened
In Steven Wayne Bonilla v. Judge Lydia Villarreal et al., Bonilla, a state prisoner representing himself, filed multiple nearly identical civil-rights complaints against various federal and state judges and other officials. He challenged his conviction and the handling of other cases in state and federal court.
The court found that Bonilla could not proceed without paying the filing fees because he had previously been barred from using the fee-waiver process, and his complaints did not show that he faced an immediate risk of serious physical harm when he filed them. The court also said that, even if he had been allowed to proceed without fees, the lawsuits would be barred by several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to end all pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them. The court also said that the judge’s impartiality could not reasonably be questioned because of the repetitive and frivolous filings.
The detailed version
- Bonilla v. Desautels · No. 4:25-cv-02063
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, a state prisoner representing himself, filed multiple civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical and named various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction and the handling of his other cases by state and federal courts.
The opinion notes that Bonilla had a pending federal petition challenging his custody with appointed counsel and was also represented by counsel in state proceedings. The court further noted his history of filing similar cases.
Fee-waiver status and legal barriers
To the extent Bonilla sought permission to proceed without paying filing fees, the court held that he was barred from doing so under 28 U.S.C. § 1915(g), unless he showed that he faced an immediate danger of serious physical harm when he filed the complaints. The court found that the allegations did not make that showing, so Bonilla could not proceed without paying the fees.
The court also stated that, even if a fee-waiver application had been granted, the lawsuits would be barred under the legal rules and decisions identified in the opinion: Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion does not separately assign a particular one of those barriers to each case.
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 the closed cases.
The court also rejected any suggestion that the judge’s impartiality could reasonably be questioned because of Bonilla’s repetitive and frivolous filings. Citing the duty of an assigned judge to decide cases absent legitimate grounds for recusal, the court continued to preside over the matters.
Judge
The order was signed by United States District Judge Phyllis J. Hamilton on March 27, 2025.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.