Bonilla v. Napa County Superior Court Judges and it's Clerks
- Phyllis Hamilton
- 4:25-cv-02513
- U.S. District Court · Northern District of California
- 3
In Bonilla v. Villarreal, Judge Hamilton dismissed with prejudice multiple civil-rights cases because Bonilla could not proceed without a filing-fee waiver and the suits were barred.
Steven Wayne Bonilla's multiple civil-rights cases were dismissed with prejudice. The named judges and other officials will not face further proceedings in these closed cases.
What happened
Steven Wayne Bonilla v. Judge Lydia Villarreal et al. involved multiple nearly identical complaints filed by Bonilla, a state prisoner, against judges and other officials. He sought relief related to his conviction and the handling of his other cases.
The court held that Bonilla could not proceed without a filing-fee waiver because he did not show that he faced an immediate danger of serious physical injury when he filed the complaints. The court also said that, even if a fee waiver were granted, the lawsuits would be barred by several legal doctrines.
Judge Phyllis J. Hamilton dismissed the cases with prejudice, ordered the clerk to terminate pending motions and close the cases, and directed the clerk to return future documents Bonilla submitted in those closed cases without filing them.
The detailed version
- Bonilla v. Napa County Superior Court Judges and it's Clerks · No. 4:25-cv-02513
- Phyllis Hamilton
- Mar. 27, 2025
Background
Steven Wayne Bonilla filed multiple nearly identical complaints without a lawyer under 42 U.S.C. § 1983, a federal law that allows certain civil-rights claims against government officials. The opinion identifies Bonilla as a state prisoner and a condemned prisoner. He named various federal and state judges and other officials as defendants. His requested relief concerned his underlying conviction or the way his other cases had been handled by state and federal courts.
The order covers numerous cases, including Case Nos. 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 related matters listed in the caption.
Reasons for dismissal
The court stated that Bonilla had previously been disqualified from proceeding in forma pauperis, meaning without paying the filing fee, under the federal law commonly called the three-strikes rule. That rule allowed him to proceed without the fee only if he showed that he was in immediate danger of serious physical injury when he filed the complaint. The court found that the allegations did not show such danger.
The court further stated that, even if a fee-waiver application 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 also noted Bonilla's extensive history of filing similar cases.
Ruling
Judge Phyllis J. Hamilton dismissed the cases with prejudice. The order also rejected the suggestion that the judge's impartiality could reasonably be questioned because of the repetitive and frivolous filings. The clerk was ordered to terminate all pending motions and close the cases, and to 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.