Bonilla v. Desautels
- Phyllis Hamilton
- 4:25-cv-02063
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Judge Lydia Villarreal, Judge Hamilton dismissed the cases with prejudice because Bonilla could not proceed without paying fees and his claims were barred.
Steven Wayne Bonilla's multiple lawsuits were dismissed with prejudice, affecting his ability to pursue the claims in these closed cases. The named federal and state judges and other officials were defendants in those lawsuits.
What happened
In Bonilla v. Judge Lydia Villarreal, Steven Wayne Bonilla, a condemned state prisoner, filed multiple similar lawsuits without a lawyer under a federal civil-rights law. He sued various federal and state judges and other officials over his conviction and the handling of his other cases.
The court said Bonilla could not proceed without paying the filing fees because his allegations did not show that he faced an immediate risk of serious physical injury when he filed. The court also said that, even if it granted his fee applications, several legal rules would bar the lawsuits.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ended all pending motions, and closed the cases. The clerk was directed to return any further documents Bonilla submitted in the closed cases without filing them.
The detailed version
- Bonilla v. Desautels · No. 4:25-cv-02063
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and condemned prisoner, filed multiple pro se civil-rights complaints under 42 U.S.C. § 1983. The complaints were nearly identical. They named various federal and state judges and other officials and sought relief concerning Bonilla's underlying conviction or the handling of his other cases in state and federal courts.
The opinion notes that Bonilla had a pending federal petition challenging his detention in the same court with appointed counsel and was also represented by counsel in state-court proceedings. The court additionally noted his history of filing similar cases.
Filing-fee restriction
The court addressed Bonilla's ability to proceed in forma pauperis, meaning without prepaying filing fees. Under 28 U.S.C. § 1915(g), the court said Bonilla was disqualified from proceeding without prepaying fees unless he was in immediate danger of serious physical injury when he filed the complaints. The court found that his allegations did not show such danger. Therefore, Bonilla could not proceed without prepaying the fees.
Other legal barriers
The court stated that, even if a fee application were granted, the lawsuits would be barred under the rules discussed in Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not separately explain which rule applied to which lawsuit or claim.
The court also rejected any suggestion that the undersigned judge's impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. It cited the principle that, absent legitimate reasons for recusal, a judge has a duty to decide cases assigned to that judge.
Ruling and case status
The court dismissed the cases with prejudice. The clerk was ordered to terminate all pending motions and close the cases. The clerk was also ordered to return, without filing, any further documents Bonilla submitted in the closed cases.
The opinion is a procedural order: the court dismissed the lawsuits based on the filing-fee restriction and other legal barriers rather than deciding the underlying claims about Bonilla's conviction or the handling of his cases.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.