Bonilla v. Katz
- Phyllis Hamilton
- 4:25-cv-02182
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed 25 pro se civil-rights cases with prejudice after finding no imminent danger and applying legal bars.
Steven Wayne Bonilla’s 25 listed civil-rights cases were dismissed with prejudice. The order concerned complaints naming various federal and state judges and other officials.
What happened
Steven Wayne Bonilla, a state prisoner, filed multiple nearly identical civil-rights 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 other cases.
The court said Bonilla could not proceed without paying the filing fee because he was barred from that status unless he faced an imminent danger of serious physical injury, which his complaints did not show. The court also said the lawsuits would be barred even if that status were granted, citing several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate all pending motions and close the cases, and directed the clerk to return future documents submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Katz · No. 4:25-cv-02182
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner, filed multiple complaints without a lawyer under 42 U.S.C. § 1983, a federal law allowing certain civil-rights claims against state actors. The complaints presented nearly identical claims and named various federal and state judges and other officials. The requested relief concerned Bonilla’s underlying conviction or the handling of his other cases by state and federal courts.
The opinion also states that Bonilla had a pending federal petition challenging his custody in the same court with appointed counsel and was represented by counsel in state-court proceedings. Those proceedings were not decided in this order.
Court’s Analysis
The court addressed Bonilla’s possible request to proceed without paying the filing fee. Under 28 U.S.C. § 1915(g), a prisoner who has been disqualified under that statute may proceed without paying only if he was in imminent danger of serious physical injury when he filed the complaint. The court stated that Bonilla had previously been disqualified and that these complaints did not show an imminent danger at the time of filing.
The court further stated that, even if Bonilla were allowed to proceed without paying the fee, the lawsuits would be barred under Heck v. Humphrey, Younger v. Harris, Demos v. U.S. District Court, or Mullis v. U.S. Bankruptcy Court. The opinion did not decide the underlying claims on their merits.
The court also rejected any suggestion that Judge Hamilton’s impartiality could reasonably be questioned because of the repetitive and allegedly frivolous filings. It cited the rule that, absent legitimate grounds for recusal, a judge has a duty to hear assigned cases.
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 those closed cases. The order also notes that Bonilla had an extensive history of filing similar frivolous cases.
The order was signed by 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.