Bonilla v. Del Norte County Superior Court
- Phyllis Hamilton
- 4:25-cv-02445
- U.S. District Court · Northern District of California
- 3
Bonilla v. Villarreal: Judge Hamilton dismissed the cases with prejudice because Bonilla did not qualify to proceed without fees and his lawsuits were barred.
Steven Wayne Bonilla and the defendants in the multiple cases were affected. The cases were dismissed with prejudice, pending motions were terminated, and the cases were closed.
What happened
In Steven Wayne Bonilla v. Judge Lydia Villarreal et al., Steven Wayne Bonilla, a state prisoner, filed multiple civil-rights cases without a lawyer. He challenged his conviction and the handling of other cases by state and federal courts, naming judges and other officials as defendants.
The court said Bonilla had already been disqualified from proceeding without paying filing fees unless he faced imminent danger of serious physical injury when he filed. The court found that his complaints did not show such danger. It also said that, even if he could proceed without paying fees, the lawsuits were barred under several legal rules and prior decisions.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, terminated all pending motions, and closed the cases. The clerk was directed to return without filing any further documents Bonilla submitted in the closed cases.
The detailed version
- Bonilla v. Del Norte County Superior Court · No. 4:25-cv-02445
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla, identified as a state prisoner and a condemned prisoner, filed multiple civil-rights complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain claims against state officials. The opinion lists these 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, 25-cv-2629-PJH, and 25-cv-2536-PJH as displayed in the opinion's caption list.
The complaints presented nearly identical claims against various federal and state judges and other officials. Bonilla sought relief concerning his underlying conviction or the handling of his other cases by state and federal courts. The opinion also noted that he had a pending federal petition challenging his conviction with appointed counsel and was represented by counsel in state court proceedings.
Proceeding Without Paying Filing Fees
The court explained that Bonilla had been disqualified under 28 U.S.C. § 1915(g) from proceeding without paying filing fees unless he was in imminent danger of serious physical injury when he filed the complaints. The court found that the allegations did not show imminent danger at the relevant time. It therefore concluded that Bonilla could not proceed without paying the fees.
Other Bars Identified by the Court
The court further stated that, even if an application to proceed without paying fees were granted, 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 provide a separate claim-by-claim analysis of which cited bar applied to which lawsuit.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The court also rejected the suggestion that its impartiality could reasonably be questioned because of the repetitive and frivolous nature of the filings. The clerk was ordered to terminate all pending motions and close the cases, and to return without filing any additional 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.